Corona vs. Senate of the Philippines

A petition for certiorari and prohibition assailing impeachment proceedings will be dismissed on the ground of mootness when the impeachment trial has concluded, the impeached official has been convicted, and the official has vacated the office, thereby extinguishing any justiciable controversy and leaving no practical relief that the court could grant.

On December 12, 2011, the majority bloc of the House of Representatives held a caucus and submitted a verified impeachment complaint against Chief Justice Renato C. Corona. The complaint was signed by 188 Members—exceeding the Constitution’s one-third vote requirement—and was immediately transmitted to the Senate. The Senate convened as an Impeachment Court on December 14, 2011. The complaint charged Corona with culpable violation of the Constitution, betrayal of public trust, and graft and corruption, including allegations of non-disclosure of assets and unexplained wealth. On January 16, 2012, the impeachment trial commenced. In the course of the trial, the Impeachment Court initially disallowed evidence on certain allegations of ill-gotten wealth but later issued subpoenas directed to the Philippine Savings Bank and the Bank of the Philippine Islands for the production of Corona’s bank records.

• Initiation of the Impeachment: On December 12, 2011, the majority bloc of the House of Representatives held a caucus during which a verified complaint for impeachment against Chief Justice Renato C. Corona was submitted by the leadership of the Committee on Justice. On the same day, the complaint was voted in session and signed by 188 Members, exceeding the one-third vote required by Article XI, Section 3(4) of the Constitution. The complaint was transmitted to the Senate on December 13, 2011.
• Charges Against Petitioner: The complaint charged Corona with culpable violation of the Constitution, betrayal of public trust, and graft and corruption under eight Articles. Article II specifically alleged that Corona failed to disclose his Statement of Assets, Liabilities and Net Worth (SALN) to the public as required by Article XI, Section 17 of the 1987 Constitution (par. 2.2); that some properties were not included in his SALN in violation of the anti-graft law (par. 2.3); and that he was suspected of accumulating ill-gotten wealth, owning high-value assets, and keeping bank accounts with huge deposits, including a 300-square-meter condominium unit in Fort Bonifacio, Taguig (par. 2.4).
• Proceedings Before the Impeachment Court: The Senate convened as an Impeachment Court on December 14, 2011. Trial commenced on January 16, 2012. On January 27, 2012, the Impeachment Court resolved to allow the prosecution to introduce evidence in support of paragraphs 2.2 and 2.3 of Article II but disallowed evidence on paragraph 2.4, stating it would rely on legal presumptions under Republic Act No. 3019 and Republic Act No. 1379. On February 6, 2012, the Impeachment Court granted the prosecution’s request for subpoenae duces tecum and ad testificandum directed to the Bank of the Philippine Islands and Philippine Savings Bank, requiring the production of documents pertaining to specific bank accounts allegedly maintained by Corona, together with year-end balances for designated years.
• Petition Before the Supreme Court: On February 8, 2012, petitioner filed the present petition for certiorari and prohibition, arguing that: (1) the impeachment complaint was constitutionally defective for lack of probable cause and was ratified with undue haste; (2) Article II contained multiple charges lacking ultimate facts and premised on suspicion and hearsay, and the Impeachment Court’s ruling on paragraph 2.3 effectively allowed a vehicle to prove the disallowed paragraph 2.4; (3) the admission of evidence on corruption and unexplained wealth violated due process because “graft and corruption” was not a stated ground in Article II and is a distinct ground under Article XI, Section 2 of the Constitution; and (4) the subpoenas were the fruit of an illegal act, as they breached the absolute confidentiality of foreign currency deposits under Republic Act No. 6426. Petitioner also sought the inhibition of Justices Antonio T. Carpio and Maria Lourdes P. A. Sereno, citing their alleged partiality. On February 9, 2012, the Court issued a TRO in G.R. No. 200238 (the PSBank petition) enjoining the Senate’s February 6, 2012 Resolution and subpoenae, and denied petitioner’s motion for inhibition. Petitioner subsequently filed a Supplemental Petition on February 13, 2012, claiming that certain Senator-Judges, particularly Senator Franklin Drilon, had lost the requisite cold neutrality and were acting as prosecutors.
• Conclusion of the Impeachment Trial: While the petition was pending, the impeachment trial concluded. Petitioner was convicted by more than the required two-thirds vote of the Senator-Judges, accepted the verdict without protest, and immediately vacated the office of Chief Justice. The Judicial and Bar Council thereafter began the process of screening applicants for the vacant post.

• Defective Impeachment Complaint: Petitioner argued that the complaint was constitutionally infirm for lack of probable cause, having been drafted and approved in a single day in a “blitzkrieg” fashion orchestrated by the President’s party mates.
• Invalidity of Article II Charges: Petitioner maintained that Article II was a “hodge-podge” of multiple charges that failed to allege ultimate facts, being premised entirely on suspicion and hearsay. Petitioner contended that the Impeachment Court’s retention of paragraph 2.3, despite disallowing paragraph 2.4, nonetheless permitted the prosecution to introduce evidence of alleged ill-gotten wealth through a backdoor, rendering the earlier resolution an empty protection.
• Due Process Violation in Admission of Evidence on Wealth: Petitioner asserted that Article II did not charge “graft and corruption” or unlawfully acquired wealth as a distinct ground for impeachment, and that “graft and corruption” is a separate ground under Article XI, Section 2 of the Constitution. Allowing evidence on such uncharged grounds violated petitioner’s right to due process.
• Confidentiality of Foreign Currency Deposits: Petitioner contended that the subpoena for his bank accounts was the “fruit of the poisonous tree,” as the underlying prosecution documents violated the absolute confidentiality of foreign currency deposits under Section 8 of Republic Act No. 6426, the violation of which is penalized under Section 10 thereof.
• Partiality of Senator-Judges: In the Supplemental Petition, petitioner claimed that certain Senator-Judges had aligned themselves with the prosecution, publicly criticized the defense, and overturned rulings of the Presiding Officer, thereby forfeiting the impartiality required of the Impeachment Court and violating his right to due process.

• Political Question and Non-Justiciability: Respondents, through the Solicitor General, argued that the petition raised purely political questions which could be decided only by the Senate and the House of Representatives. Citing Nixon v. United States, respondents contended that subjecting the impeachment trial to judicial review would frustrate the constitutional design and result in needless delay beyond the terms of the Senator-Judges.
• No Grave Abuse of Discretion: Respondents maintained that the Impeachment Court conducted the proceedings judiciously and that none of its actions constituted grave abuse of discretion. The issuance of the subpoenae was a valid exercise of its fact-finding function, and the constitutional mandate of public accountability prevailed over petitioner’s claim of bank confidentiality.
• Exclusive Constitutional Limitations: Respondents argued that the only limitations on the Senate’s power to try impeachments are those expressly enumerated in the Constitution, none of which was violated. The Senator-Judges’ questioning of witnesses was a proper discharge of their adjudicative function and did not prove partiality.

• Mootness: Whether the petition had become moot and academic by reason of the conclusion of the impeachment trial, petitioner’s conviction, and his vacation of the office of Chief Justice.
• Judicial Review of Impeachment Matters: Whether the Supreme Court’s certiorari jurisdiction may be invoked to review incidents arising from impeachment proceedings and to grant injunctive relief for alleged violations of due process.

• Mootness: The petition was dismissed as moot and academic. The impeachment trial had concluded with the conviction of petitioner by more than the required majority vote of the Senator-Judges, and petitioner had accepted the verdict and immediately vacated his office. The constitutional issues he raised were thus overtaken by supervening events and his own acts. A case becomes moot when it ceases to present a justiciable controversy, so that a determination thereof would be without practical use and value. In such circumstances, no actual substantial relief could be granted to petitioner, and the dismissal of the petition negated no relief to which he would have been entitled.
• Judicial Review of Impeachment Matters: The issue was not reached. Although the Court acknowledged its earlier pronouncements in Francisco, Jr. v. Nagmamalasakit na mga Manananggol ng mga Manggagawang Pilipino, Inc. and Gutierrez v. House of Representatives Committee on Justice that justiciable issues in impeachment proceedings may be subject to judicial review, the supervening events rendered any ruling on the merits unnecessary. Dismissal on the preliminary ground of mootness was therefore proper.

• Mootness Doctrine — An issue or a case becomes moot and academic when it ceases to present a justiciable controversy, such that a determination of the merits would have no practical use and value. In such a case, there is no actual substantial relief to which the petitioner would be entitled, and the petition must be dismissed. The doctrine was applied because petitioner’s conviction and acceptance of the verdict eliminated the live controversy over the validity of the impeachment proceedings and the reliefs sought.

• “An issue or a case becomes moot and academic when it ceases to present a justiciable controversy so that a determination thereof would be without practical use and value. In such cases, there is no actual substantial relief to which the petitioner would be entitled to and which would be negated by the dismissal of the petition.” — This passage articulates the controlling standard for dismissal on grounds of mootness and is the ratio decidendi of the Resolution.

• Francisco, Jr. v. Nagmamalasakit na mga Manananggol ng mga Manggagawang Pilipino, Inc., G.R. Nos. 160261, November 10, 2003, 415 SCRA 44 — Recognized as the first impeachment case decided by the Supreme Court, holding that the power of judicial review in this jurisdiction extends to justiciable issues in impeachment proceedings. Cited to establish the general availability of judicial review, though not applied here.
• Gutierrez v. House of Representatives Committee on Justice, G.R. No. 193459, February 15, 2011, 643 SCRA 199 — Cited as a subsequent instance where the Court resolved the validity of simultaneous referral of two impeachment complaints, affirming the justiciability of certain aspects of the impeachment process.
• Philippine Airlines, Inc. v. Pascua, G.R. No. 143258, August 15, 2003, 409 SCRA 195 — Cited for the definition of mootness.
• Vda. de Dabao v. Court of Appeals, G.R. No. 116526, March 23, 2004, 426 SCRA 91 — Cited for the principle that dismissal of a moot petition does not negate any substantial relief to which the petitioner would have been entitled.

• Constitution, Article VIII, Section 1 — The judicial power to settle actual controversies involving legally demandable and enforceable rights. The requirement of an actual justiciable controversy underpins the dismissal for mootness.
• Constitution, Article XI (Accountability of Public Officers) — The impeachment provisions, specifically Section 2 (grounds for impeachment), Section 3(4) (initiation by one-third vote of House members), and Section 17 (disclosure of SALN). These provisions formed the substantive context of the challenged impeachment proceedings but were not applied in the dismissal.

Associate Justice Martin S. Villarama, Jr. (ponente). Concurring: Senior Associate Justice Antonio T. Carpio (no part), Associate Justice Presbitero J. Velasco, Jr., Associate Justice Teresita J. Leonardo-De Castro, Associate Justice Arturo D. Brion (on leave), Associate Justice Diosdado M. Peralta, Associate Justice Lucas P. Bersamin, Associate Justice Mariano C. Del Castillo (no part), Associate Justice Roberto A. Abad, Associate Justice Jose Portugal Perez, Associate Justice Jose Catral Mendoza, Associate Justice Maria Lourdes P.A. Sereno, Associate Justice Bienvenido L. Reyes, Associate Justice Estela M. Perlas-Bernabe.

N/A. No dissenting opinions were recorded. Justices Carpio and Del Castillo took no part; Justice Brion was on leave.