G.R. No. 104786 - Patalinghug vs. Court of Appeals

Bernardino Marcelino, the petitioner, was charged with rape before the Court of First Instance of Rizal, Branch XII.
The trial was conducted and concluded when the accused rested his case on August 4, 1975, following which both parties’ attorneys moved for a period within which to file their respective memoranda.

By joint motion, the trial court granted the parties thirty (30) days to simultaneously submit their memoranda, after which the case would be deemed submitted for decision.
The petitioner’s counsel duly submitted his memorandum, whereas the People did not file any memorandum.
On November 28, 1975 – eighty-five (85) days after the case was deemed submitted (calculated from September 4, 1975) – the trial judge filed with the Deputy Clerk of Court his decision in Criminal Case No. C-5910.
The decision, dated November 28, 1975, was accompanied by notices posted via registered mail on December 4, 1975, and received by the concerned parties between December 2 and December 9, 1975.

On the set date for promulgation of the decision, counsel for the accused moved to postpone the promulgation, raising for the first time the alleged loss of jurisdiction of the trial court for allegedly failing to decide the case within the 90-day period mandated by the Constitution.
Accommodating the counsel's request to consider the proper remedial measure, the trial judge rescheduled the promulgation first to January 19, 1976, and then, following another motion by counsel for the petitioner, to January 26, 1976.
Meanwhile, on January 12, 1976, counsel for the accused filed a petition for prohibition and a writ of habeas corpus before the Supreme Court seeking the release of the petitioner on the ground that the trial court had lost jurisdiction due to the delay.

The petitioner argued that Section 11(1) of Article X of the 1973 Constitution, prescribing a 90-day period for deciding a case from its submission, was mandatory and that exceeding such period would result in loss of jurisdiction of the trial court over the unresolved matter.
The petition further sought an injunction to restrain respondent Judge Fernando Cruz, Jr. from promulgating his decision in Criminal Case No. C-5910.
A temporary restraining order was issued by the Supreme Court on January 16, 1976, pending the resolution of the petition.

It was noted that the petition’s central thesis hinged on the interpretation of “rendering of judgment”—specifically, whether the date of filing the signed decision (as opposed to the later date of promulgation) is the critical moment in determining compliance with the constitutional 90-day rule.
Subsequent observations by a concurring judge (Abad Santos, J.) reinforced that the validity of a decision is not jeopardized merely because it was promulgated outside the 90-day period, but merely triggers administrative sanctions against the judge responsible for the delay.
The respondent judge had since passed away, necessitating that another judge assume the responsibility to decide the case.

Whether the trial court lost its jurisdiction over Criminal Case No. C-5910 for allegedly failing to decide the case within the 90-day period prescribed by Section 11(1) of Article X of the Constitution.
Whether the “rendering” of judgment refers to the filing of the signed decision with the clerk of court, or to the later promulgation of said decision.
Whether the constitutional time limit for decision rendering is to be regarded as a mandatory sanction affecting the court’s jurisdiction, or as a directory (procedural) provision that may be liberally applied.
What administrative or remedial consequences should be imposed on judges who exceed the prescribed period, without invalidating the decision itself.