G.R. No. 45685 - People vs. Vera

Bernardino B. Blancaflor, a former temporary stenographer of the Court of First Instance of Rizal, Pasay City Branch, was directed by this Court on July 30, 1976, to submit his transcript of stenographic notes taken on October 20, 1973, in Criminal Cases Nos. 633-P and 935-P within thirty days from notice.
He was also required to show cause as to why disciplinary measures should not be imposed for failing to submit the transcript by the designated deadline (June 17, 1976).

Blancaflor did not comply with the directive and consequently, a fine of ₱200 was imposed on him in the Court’s resolution dated February 14, 1977.
On May 19, 1977, Blancaflor moved to lift the fine, explaining that he did not transcribe the notes because they might have been lost when his residence burned on December 15, 1974. He suggested the retaking of the witness testimony from that session.

The matter was referred to the Executive Judge of the Pasay court for further investigation. Judge Pedro J.L. Bautista directed Blancaflor to appear or execute an affidavit to explain the alleged loss of his stenographic notes.
Blancaflor failed to comply with the directive. Judge Bautista’s report confirmed that Blancaflor did not submit the stenographic notes or transcripts thereof to the branch clerk of court or the clerk handling criminal cases in Criminal Cases Nos. 633-P and 935-P, thus violating Section 17, Rule 136 of the Rules of Court. The relevant guidelines were supported by Circular No. 115, series of 1966, issued by the Secretary of Justice.

The Court took into account Blancaflor’s history of inefficiency, noting his previous failures to submit transcripts on time in other cases, including Arahan vs. Aboitiz Shipping Corporation (CA-G.R. No. 59230-R), Sobrepena vs. Sobrepena (CA-G.R. No. 59220-R), People vs. Libutan (CA-G.R. No. 19956-Cr.), and Navarro vs. Vibal (CA-G.R. No. 62107-R).
Despite his expiration of appointment on January 15, 1975, Blancaflor had been reappointed in 1976 and was, at the time the decision was rendered, serving as temporary stenographer in the Court of First Instance of North Cotabato, Kidapawan Branch V, with his term set to expire on March 6, 1979.

The Court severely censured Blancaflor for the loss of his stenographic notes and confirmed the ₱200 fine.
Additionally, the Court resolved that his temporary appointment should not be renewed upon its expiration. The Presiding Judge of the Court of First Instance of North Cotabato was instructed to require Blancaflor to transcribe his notes before his appointment ended, thereby emphasizing immediate compliance with procedural requirements.

Whether Bernardino B. Blancaflor failed to comply with the Court’s order to submit his stenographic transcript, despite the extensions provided.
Whether his failure constituted a violation of Section 17, Rule 136 of the Rules of Court, particularly regarding the immediate delivery of stenographic notes after a session.

Whether the alleged loss of stenographic notes due to the burning of his residence on December 15, 1974, was a sufficient justification for his non-compliance.
Whether the suggested remedy of retaking the witness testimony was a viable alternative to prevent or mitigate disciplinary action.

Whether the imposition of a ₱200 fine and severe censure was appropriate given the circumstances and Blancaflor’s history of inefficiency.
Whether the court's decision to not renew his temporary appointment was justified in light of his recurring non-compliance in submitting required transcripts.