G.R. No. 200242 - Corona vs. Senate of the Philippines

On December 12, 2011, the House of Representatives’ majority bloc caucus endorsed a verified impeachment complaint against Chief Justice Renato C. Corona, securing 188 signatures (above the one‐third constitutional requirement).
The complaint was transmitted to the Senate on December 13, 2011; the Senate convened as an Impeachment Court on December 14, and Corona received formal notice on December 15, 2011.

Article I alleged betrayal of public trust through partiality and subservience in cases favoring the Arroyo administration.
Article II charged failure to publicly disclose SALNs, unreported properties, and suspected ill‐gotten wealth.
Articles III–VIII accused Corona of breach of constitutional standards for the judiciary, contempt for separation of powers, wanton arbitrariness (res judicata violations), unauthorized investigations of justices, partiality in granting TROs, and failure to account for Judiciary funds.

On December 26, 2011, Corona filed a petition for certiorari and prohibition with prayer for TRO/preliminary injunction, assailing procedural infirmities and political motives.
The prosecuting panel held press conferences disclosing alleged properties and bank accounts, prompting Senate reprimands per impeachment rules.
Senate trial commenced January 16, 2012; Corona’s preliminary hearing motion was denied.
Senate subpoenaed Supreme Court Clerk for Corona’s SALNs (Jan 18); prosecution and defense filed memoranda on evidence admissibility for Articles II §§ 2.2–2.4.
Senate Resolutions:

January 27, 2012 – allowed evidence on SALN nondisclosure and unreported properties, disallowed ill‐gotten wealth evidence per RA 3019/RA 1379 presumptions.
February 6, 2012 – subpoenaed BPI and PSBank officers to produce opening documents and statements for multiple accounts (2005–2010).

PSBank filed certiorari petition (G.R. No. 200238) to enjoin the subpoenas; SC issued TRO on February 9, 2012.
On February 13, 2012, Corona filed a supplemental petition claiming due process violations by allegedly partial Senator‐Judges aiding the prosecution.

Respondents (Solicitor General and House prosecutors) argued impeachment is a political question non‐justiciable by SC, and Senate acted within constitutional bounds; public accountability supersedes confidentiality.
Senate convicted Corona by requisite majority; he accepted verdict, vacated office, and the Judicial and Bar Council proceeded to fill the vacancy.

Does the SC’s certiorari jurisdiction extend to procedural incidents and alleged arbitrariness in an ongoing impeachment trial?
Do political question and separation‐of‐powers doctrines bar SC intervention?

Was it grave abuse of discretion to admit evidence on unreported SALN properties and bank accounts?
Did subpoenas for bank records violate confidentiality under RA 6426 (Foreign Currency Deposits Act)?

Has Corona’s conviction and vacatur of office rendered the petition moot and non‐justiciable?