Lack of transcript of stenographic notes shall not be a valid reason to interrupt or suspend the period for deciding the case unless the case was previously heard by another judge not the deciding judge in which case the latter shall have the full period of ninety (90) days from the completion of the transcripts within which to decide the same.

OFFICE OF THE COURT ADMINISTRATOR  vs. JUDGE BORROMEO R. BUSTAMANTE, MUNICIPAL TRIAL COURT IN CITIES, ALAMINOS CITY, PANGASINAN, A.M. No. MTJ-12-1806, (Formerly A.M. No. 11-4-36-MTCC), April 7, 2014

“x x x. In Administrative Circular No. 28, dated July 3, 1989, the Supreme Court provided that "A case is considered submitted for decision upon the admission of the evidence of the parties at the termination of the trial. The ninety (90) days period for deciding the case shall commence to run from submission of the case for decision without memoranda; in case the court requires or allows its filing, the case shall be considered submitted for decision upon the filing of the last memorandum or the expiration of the period to do so, whichever is earlier. Lack of transcript of stenographic notes shall not be a valid reason to interrupt or suspend the period for deciding the case unless the case was previously heard by another judge not the deciding judge in which case the latter shall have the full period of ninety (90) days from the completion of the transcripts within which to decide the same." x x x (Emphasis supplied, citations omitted.).”