Read - sc.judiciary.gov.ph/jurisprudence/2013/june2013/MTJ-11-1778.pdf
"x x x.
Section 15(1), Article VIII of the 1987 Constitution, mandates that cases or matters filed with the lower courts must be decided or resolved within three months from the date they are submitted for decision or resolution. With respect to cases falling under the 1991 Revised Rule on Summary Procedure, first level courts are only allowed 30 days following the receipt of the last affidavit and position paper, or the expiration of the period for filing the same, within which to render judgment. Section 6 of the said Rule also requires first level courts to render judgment motu proprio or
upon motion of the plaintiff if the defendant fails to file an answer to the
complaint within the allowable period.
x x x."
