Title
People vs. De Leon
Case
G.R. No. L-40884
Decision Date
Aug 22, 1978
Former stenographer fined P200 for failing to submit transcripts, citing a house fire. Court upheld fine, censured inefficiency, and denied appointment renewal due to repeated lapses.

Case Summary (G.R. No. L-40884)

Failure to Comply with Court Orders

On July 30, 1976, this Court issued a resolution demanding Blancaflor submit a transcript of the stenographic notes taken on October 20, 1973, as part of Criminal Cases Nos. 633-P and 935-P. He was given a grace period of thirty days to comply and to demonstrate why disciplinary measures should not be enacted due to his previous failure to submit the transcript by the original due date of June 17, 1976. Blancaflor's failure to adhere to this directive resulted in a sanction of a fine of P200, imposed on February 14, 1977.

Claim of Lost Notes

On May 19, 1977, Blancaflor filed a motion to lift the fine, citing that the stenographic notes from the hearing might have been lost due to a fire that consumed his residence on December 15, 1974. He proposed that the testimony of the witnesses be retaken rather than producing the lost notes. In light of this situation, the Court referred the matter to Judge Pedro J.L. Bautista, Executive Judge of the Pasay court, for further investigation.

Investigative Findings

Judge Bautista required Blancaflor to appear or submit an affidavit to explain the loss of the stenographic notes. Blancaflor's non-compliance with this directive was noted, and the judge reported that Blancaflor failed to deliver the stenographic notes or transcripts as mandated by Section 17, Rule 136 of the Rules of Court, which requires immediate delivery to the clerk of court upon the session's conclusion. This failure constituted a significant breach of duty.

Disciplinary Recommendations and Court Decision

In a resolution dated January 30, 1978, Blancaflor was asked to comment on Judge Bautista's report and to demonstrate why disciplinary action should not be taken against him. He did not submit any feedback regarding the findings. His appointment as a temporary stenographer had lapsed on January 15, 1975, yet he was reappointed in 1976 and currently served in the Court of First Instance of North Cotabato.

Given Blancaflor’s inefficient performance, illustrated by his inability to timely submit the transcripts in multiple cases, the Court decided to sever

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