Case Digest (G.R. No. 197164) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines v. Maria Lourdes P. A. Sereno, G.R. No. 237428, decided June 19, 2018, the Office of the Solicitor General (OSG) filed an original petition for quo warranto before the Supreme Court, challenging then Chief Justice Sereno’s right to hold office on the ground that she was ineligible due to her prior failure to file several Statements of Assets, Liabilities, and Net Worth (SALNs), a constitutional requirement for members of the Judiciary. On May 11, 2018, the Court granted the petition, finding Sereno guilty of unlawfully holding and exercising the Chief Justice’s office, ousting and excluding her and declaring the position vacant. The Court directed the Judicial and Bar Council (JBC) to commence the nomination process and ordered Sereno to show cause why she should not be sanctioned for alleged ethical violations. Sereno then filed an Ad Cautelam Motion for Reconsideration and a motion for extension to reply to the show-cause order, contending denial Case Digest (G.R. No. 197164) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petition
- Republic of the Philippines, represented by Solicitor General Jose C. Calida, filed an original petition for quo warranto against Maria Lourdes P. A. Sereno before the Supreme Court en banc.
- The petition alleged that respondent was disqualified for failing to submit Statements of Assets, Liabilities, and Net Worth (SALNs) covering certain years, thereby lacking the constitutional qualification of proven integrity.
- May 11, 2018 Decision
- The Supreme Court en banc granted the petition: it adjudged respondent guilty of unlawfully holding and exercising the Office of Chief Justice, ousted her from that position, declared the vacancy, and directed the Judicial and Bar Council (JBC) to commence a new nomination process.
- The Court issued a Show Cause Order directing respondent to explain why she should not be sanctioned for alleged sub judice violations and aspersions cast on other justices.
- Post-Decision Motions
- Respondent filed an “Ad Cautelam” Motion for Reconsideration of the May 11, 2018 Decision, asserting denial of due process, allegations of bias, lack of jurisdiction, reliance on extraneous evidence, procedural infirmities, exclusivity of impeachment, prescription, and her own integrity.
- She also moved for extension of time to reply to the Show Cause Order. The Republic, through the Office of the Solicitor General, filed Comments opposing reconsideration and underscoring the merits of quo warranto, the justiciability of integrity, and inapplicability of prescription.
Issues:
- Due Process and Impartial Tribunal
- Whether respondent was denied due process by an impartial tribunal.
- Whether six justices should have inhibited themselves for bias or pre-judgment.
- Extraneous Evidence and Procedural Rules
- Whether the Court improperly took notice of extraneous matters as “corroborative evidence.”
- Whether the Court violated mandatory procedure for reception of evidence.
- Jurisdiction Over Impeachable Officers
- Whether the Supreme Court has original jurisdiction to oust an impeachable officer by quo warranto.
- Whether impeachment is the exclusive mode of removal for respondents.
- Prescription and Public Interest
- Whether the petition was time-barred under Section 11, Rule 66 of the Rules of Court.
- Whether prescription applies to an action brought by the State.
- Integrity Qualification
- Whether respondent’s failure to file SALNs defeated the constitutional requirement of proven integrity.
- Whether SALN non-filing is malum prohibitum and unrelated to integrity.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)