Case Digest (G.R. No. 237428)
Facts:
Republic of the Philippines, represented by Solicitor General Jose C. Calida v. Maria Lourdes P. A. Sereno, G.R. No. 237428, June 19, 2018, Supreme Court En Banc, Tijam, J., writing for the Court.The Office of the Solicitor General (OSG) filed a petition for quo warranto challenging Maria Lourdes P. A. Sereno’s right and title to the office of Chief Justice, alleging she lacked the constitutional qualification of “proven integrity” because she failed to file several Statements of Assets, Liabilities and Net Worth (SALNs) and misled the Judicial and Bar Council (JBC) during the 2012 application process. The Court initially heard the petition (including oral argument set in Baguio), took judicial notice of documentary certifications from the University of the Philippines Human Resources Department Office and the Ombudsman, and on May 11, 2018 granted the quo warranto petition, adjudged respondent disqualified and ousted her from office, and declared the Chief Justice position vacant.
Respondent filed an Ad Cautelam Motion for Reconsideration claiming (inter alia) denial of due process because six Justices should have inhibited themselves for actual bias or personal knowledge; that the Court lacked jurisdiction to oust an impeachable officer by quo warranto; that the petition was time‑barred; and that she was a person of proven integrity. The OSG opposed the motion, reiterating that quo warranto was the proper remedy, that the prescriptive period did not bar a petition filed by the State at its own instance, and that the SALN certifications established respondent’s non‑filing until rebutted.
This Resolution resolves respondent’s Motion for Reconsideration (and an accompanying motion for extension to file a reply to the Show Cause Order). The Court reviewed the pleadings, the record (including JBC and repository certifications), its prior May 11, 2018 Decision, and supplemental arguments, and denied reconsideration, reaffirming jurisdiction to entertain quo warranto against impeachable officers, the non‑applicability of t...(Subscriber-Only)
Issues:
- Did respondent suffer denial of due process because certain Justices should have inhibited themselves and the tribunal was therefore not impartial?
- Does the Supreme Court have jurisdiction to oust an impeachable officer through quo warranto?
- Was the OSG’s quo warranto petition time‑barred under the one‑year prescription in Section 11, Rule 66 of the Rules of Court?
- Did respondent prove the constitutional qualification of “proven integrity,...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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