Court Stenographers' Duty to Transcribe Notes: A Lesson in Timely Justice

The Supreme Court has long emphasized that justice delayed is justice denied. A key component of this principle rests on the shoulders of court stenographers, whose timely transcription of notes is essential for judges to decide cases. In a 2000 resolution, the Court clarified the non-negotiable duty of stenographers to transcribe their notes within a fixed period and underscored that administrative excuses cannot justify delay.

The Case: A Judicial Audit Uncovers Delays

In April 1999, the Office of the Court Administrator conducted a judicial audit of several courts in Davao City. The audit revealed that Civil Case No. 20394, pending before the Regional Trial Court (RTC), Branch 15, could not be decided because transcripts of stenographic notes were missing. The case had been submitted for decision in December 1998, but the judge could not rule without the transcripts.

Three stenographers had failed to transcribe their notes: Olanda Apilado (notes from December 1990 and March 1991), Sarah Dujali (notes from March 1991), and Marianita Bandalan (notes from July 1998). The Court directed them to explain why no disciplinary action should be taken.

The Issue: Did the Transfer of the Case Excuse the Delay?

Stenographer Sarah Dujali explained that Civil Case No. 20394 was originally assigned to RTC, Branch 14, where she worked. She took stenographic notes on March 8, 1991. Years later, in 1994 and 1995, the case was transferred to Branch 15 due to a conflict of interest involving the presiding judge. Dujali claimed she had no knowledge of the proceedings after the transfer and only learned of her duty to transcribe when the new judge directed her to do so. She complied on September 13, 1999.

The Supreme Court was not persuaded. The issue was whether the transfer of the case excused Dujali from her duty to transcribe her notes within the prescribed period.

The Ruling: A Stenographer's Duty Is Fixed and Unconditional

The Court held Dujali liable for violating Administrative Circular No. 24-90, which took effect on August 1, 1990. This circular mandates all court stenographers to transcribe their stenographic notes and attach the transcripts to the case record not later than twenty (20) days from the time the notes are taken.

Dujali took the notes on March 8, 1991. She should have transcribed and submitted them to the Clerk of Court within twenty days from that date. The Court noted that Dujali offered no explanation for her failure to meet this deadline. The transfer of the case to Branch 15 and the subsequent order of the new judge did not excuse her delay—these events happened four years after she took the notes. The duty to transcribe was hers alone, and it arose immediately upon taking the notes, regardless of what happened to the case later.

The Court imposed a fine of One Thousand Pesos (P1,000.00) on Dujali, with a warning that repetition of the same offense would be dealt with more severely.

Why This Matters

This resolution reinforces several important principles in Philippine judicial administration:

• Fixed deadlines are absolute. The 20-day period under Administrative Circular No. 24-90 is not a mere guideline. It is a mandatory rule.
• No "passing the buck." A stenographer cannot rely on case transfers or other administrative events to excuse a delay in transcription.
• The integrity of the record. Transcripts are the foundation of a judge's decision. Without them, cases stall, and litigants suffer.

Practical Takeaways

• Stenographers must transcribe notes within 20 days from the date they are taken, as mandated by Administrative Circular No. 24-90. This duty is personal and cannot be delegated or deferred.
• Case transfers do not reset deadlines. A stenographer remains responsible for transcribing notes taken before a case is transferred, even if the new court issues orders about the case.
• Administrative excuses are scrutinized. The Court will not accept vague explanations or claims of ignorance when a clear administrative rule has been violated.
• Delays in transcription delay justice. Judges cannot decide cases without complete transcripts, and the entire judicial system suffers when one officer of the court fails in this duty.
• Penalties are real. Violations carry fines and the threat of more severe sanctions for repeat offenses.

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