Timely Justice Reckoning Deadlines In Default Order Motions

The 90-day period within which a judge must resolve a motion does not always start from the date the motion is filed. In Spouses Guevarra v. Judge Maceda (A.M. No. 03-1787-RTJ, July 14, 2003), the Supreme Court clarified that the clock begins only when the matter is deemed submitted for resolution — typically upon filing of the last pleading. This ruling offers practical guidance for litigants tracking court deadlines and for understanding what constitutes "undue delay" in judicial service.

The Case: A Motion to Declare Default That Sat Unresolved

The complainants, Spouses Rodolfo and Violeta Guevarra, were plaintiffs in a civil case before the Regional Trial Court of Las Piñas City, Branch 275, presided by Judge Bonifacio Sanz Maceda. After the defendants filed a Motion to Dismiss, the trial court denied it on October 29, 2001. When the defendants failed to file an answer, the plaintiffs moved to declare them in default on January 4, 2002.

The defendants countered with a Motion to Admit Answer on January 14, 2002, which the plaintiffs opposed. On February 14, 2002, the defendants filed an Affidavit of Merit to support their motion. Over the following months, the plaintiffs filed several motions urging the judge to resolve the default motion. By April 2002, with no resolution in sight, they filed an administrative complaint for gross inefficiency against the judge.

The Issue: When Does the 90-Day Period Start?

The central question was whether the judge violated the constitutional requirement to resolve motions within 90 days from submission. The complainants argued that the period should be counted from January 4, 2002, when they filed their Motion to Declare Defendants in Default. The judge, however, contended that the period should run from February 14, 2002, when the defendants filed their Affidavit of Merit — the last pleading on the matter.

The Ruling: Counting from the Last Pleading

The Supreme Court sided with the judge. Under Section 15(1), Article VIII of the Constitution, lower courts must resolve cases or matters within three months from the date of submission. Section 15(2) clarifies that a case or matter is deemed submitted upon the filing of the last pleading, brief, or memorandum required by the Rules of Court or by the court itself.

Since the defendants' Motion to Admit Answer and the plaintiffs' Motion to Declare Default were interrelated and could be resolved jointly, the Court treated them as one matter. The Affidavit of Merit, filed on February 14, 2002, was the last pleading that completed the submissions. The 90-day period therefore lapsed on May 15, 2002. The judge issued his Order on May 13, 2002 — two days before the deadline. The administrative complaint, filed on April 26, 2002, was thus premature.

Why This Matters for Litigants

The ruling underscores that litigants cannot simply count 90 days from the filing of their own motion. If opposing parties file responsive pleadings, the period resets. A motion is not "ripe for resolution" until all related pleadings are in. Filing an administrative complaint before the period lapses may be dismissed as premature, wasting time and resources.

The Court also reminded judges that default orders are generally disfavored, as they decide cases on technicalities rather than on the merits. This reflects a policy preference for resolving disputes on their substance.

Practical Takeaways

• Track the last pleading, not the first. The 90-day period for a judge to resolve a motion starts when the last required pleading is filed, not when the motion was initially submitted.
• Related motions may be resolved jointly. If a motion to declare default and a motion to admit answer concern the same issue, they may be treated as one matter for purposes of counting the period.
• Do not file administrative complaints prematurely. Verify that the reglementary period has actually lapsed before charging a judge with undue delay.
• Default orders are disfavored. Courts prefer to decide cases on their merits, so expect courts to be cautious in granting motions to declare default.
• Keep records of all pleadings. Documenting the dates of every filing helps compute deadlines accurately and supports any future administrative action.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.