This is my typical Christmas movie and is something I've noticed before, but I kept track tonight. I think this goes to show how this movie is so much more about the villains than it is about Batman.
His first appearance is at 13:04. He then has a brief fight with Penguin's gang and has his first line at 17:05, "we'll see." He then goes missing for nearly 20 minutes until he and Alfred are watching the Penguin on the news and he finally has his second line of the movie.