Case Digest (G.R. No. 200242)
Facts:
Chief Justice Renato C. Corona v. Senate of the Philippines sitting as an Impeachment Court, G.R. No. 200242, July 17, 2012, the Supreme Court En Banc, Villarama, Jr., J., writing. The petition for certiorari and prohibition with prayer for a TRO and writ of preliminary injunction was filed by former Chief Justice Renato C. Corona challenging the impeachment complaint filed by Members of the House of Representatives and the trial conducted by the Senate sitting as an Impeachment Court; several private parties and bank respondents were also named in the proceedings below.On December 12–13, 2011, a verified complaint for impeachment was presented and endorsed by the House with more than the constitutional one‑third vote, and was transmitted to the Senate which convened as an Impeachment Court on December 14, 2011. On December 15, 2011, petitioner received the Articles of Impeachment charging, inter alia, betrayal of public trust, culpable violation of the Constitution (including alleged failure to disclose SALNs under Art. XI, Sec. 17), graft and corruption, partiality in decisions involving the Arroyo administration, improper interference with other branches, and failure to account for judiciary funds.
Petitioner filed an Answer on December 26, 2011, denying the allegations and assailing the haste and verification of the complaint. The prosecution publicly disclosed purported evidence and alleged properties and bank accounts; the Impeachment Court began trial proceedings on January 16, 2012. The Impeachment Court denied a motion for preliminary hearing, took testimony and produced petitioner’s SALNs under subpoena, and considered memoranda on whether evidence could be presented to prove certain paragraphs of Article II (notably paras. 2.2, 2.3 and 2.4).
On January 27, 2012, the Impeachment Court ruled it would allow evidence on paragraphs 2.2 and 2.3 but disallow evidence on paragraph 2.4, and referenced legal presumptions under R.A. No. 3019, Sec. 8 and R.A. No. 1379, Sec. 2. On February 6, 2012, the Court granted subpoenas ad testificandum et duces tecum to officers of Bank of the Philippine Islands (BPI) and Philippine Savings Bank (PSBank) to produce account opening documents and year‑end balances for specified accounts. On February 8, 2012, PSBank filed a separate certiorari petition (G.R. No. 200238) to enjoin enforcement of that subpoena.
On February 8, 2012, petitioner filed the present petition (G.R. No. 200242) seeking immediate injunctive relief, annulment of the impeachment complaint as void ab initio, nullification of the Impeachment Court resolutions (including the subpoenas), and permanent injunctive relief; he also sought inhibition of Justices Carpio and Sereno. On February 9, 2012, this Court issued a TRO in G.R. No. 200238 enjoining the Senate from implementing the February 6, 2012 Resolution and subpoena; the Court denied petitioner's inhibition motion for lack of compulsory ground and voluntary inhibition.
Petitioner later filed a Supplemental Petition alleging that certain Senator‑Judges had abandoned impartiality. The Solicitor General filed a Comment ad cautelam arguing the matters were political and cited Nixon v. United States, 506 U.S. 224 (1993). Before this Court could resolve the merits, the Impeachment Court concluded its trial and convi...(Subscriber-Only)
Issues:
- May the certiorari jurisdiction of the Supreme Court be invoked to assail matters or incidents arising from impeachment proceedings and to obtain injunctive relief for alleged violations of the due process rights of a person tried by the Senate sitting as an Impeachment Court?
- Is the present petition justiciable or is it rendered moot by the conclusion of the impeachment trial, the conviction of petitioner a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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