Case Digest (G.R. No. 237428)
Facts:
Republic of the Philippines, represented by the Solicitor General, filed a petition for quo warranto against Maria Lourdes P.A. Sereno, then incumbent Chief Justice, to question the validity of her appointment. The petition arose after the Judicial and Bar Council (JBC) required, in its June 4, 2012 En Banc meeting and June 5, 2012 announcement, that applicants for Chief Justice from government submit all previous Statements of Assets, Liabilities and Net Worth (SALNs) up to December 31, 2011, together with a bank waiver. Respondent had served as faculty at the University of the Philippines College of Law from November 1986 until June 1, 2006, and had also been engaged as legal counsel in the PIATCO and Fraport arbitration cases. Records from the UP Human Resources Development Office and the Office of the Ombudsman showed SALNs on file for some years, but not for several others during her government service. When respondent applied for Chief Justice in July 2012, she submitted only her 2009, 2010, and 2011 SALNs and a letter dated July 23, 2012 explaining that she had been in private practice after 2006 and that it was infeasible to retrieve older records. The JBC nonetheless included her in the shortlist submitted to the President, who appointed her Chief Justice in August 2012. Years later, an impeachment complaint was filed against her in the House of Representatives, and hearings revealed, according to the Republic, that she had not filed several SALNs and that members of the JBC were not made aware of the July 23, 2012 letter. During the pendency of the case, respondent filed an initial Comment Ad Cautelam that was later verified, and several groups moved to intervene or sought to inhibit certain Justices. The Court heard oral arguments, ...(Subscriber-Only)Issues:
Whether quo warranto was a proper remedy to challenge the appointment of an impeachable officer such as the Chief Justice?Whether the petition was barred by the one-year period under Rule 66, Section 11, Rules of Court?
Whether respondent possessed the constitutional qualification of proven integrity despite the alleged failure to file SALNs for several years and the circumstances surrounding her JBC application?
Whether the Court had b...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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