Case Summary (G.R. No. 200242)
Applicable Law
1987 Philippine Constitution:
- Art. XI, Sec. 17 (Statement of Assets, Liabilities, and Net Worth disclosure)
- Art. VIII, Sec. 7(3) (Judicial integrity, probity, and independence)
Impeachment Rules (Senate Rule XVIII)
Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act)
Republic Act No. 1379 (Presumption in favor of registered property)
Republic Act No. 6426 (Foreign Currency Deposits Act)
Key Dates
December 12–13, 2011: Verified impeachment complaint endorsed by 188 House Members; transmitted to Senate
December 14, 2011: Senate convened as Impeachment Court
December 15, 2011: Petitioner formally charged under eight articles (betrayal of public trust, culpable violation of the Constitution, graft and corruption)
January 16, 2012: Trial commenced before the Impeachment Court
January 27, 2012: Court resolution allowing evidence on SALN nondisclosure (Art. II, pars. 2.2–2.3) but disallowing proof of ill-gotten wealth (par. 2.4)
February 6, 2012: Subpoenas issued to BPI and PSBank for bank records
February 8, 2012: PSBank filed certiorari petition to enjoin enforcement of subpoenas
February 9, 2012: Supreme Court issued TRO enjoining enforcement of Senate subpoenas and denied motion to inhibit Justices Carpio and Sereno
July 17, 2012: Supreme Court resolved petition moot and dismissed it
Impeachment Complaint and Articles
The complaint charged Corona with:
• Article I – Subservience and partiality favoring the Arroyo administration
• Article II – Failure to publicly disclose SALNs (Art. XI, Sec. 17) and alleged undeclared properties and bank accounts, suspected ill-gotten wealth
• Article III – Breach of integrity and probity by flip-flopping decisions, excessive entanglement with Mrs. Arroyo, improper discussions with litigants (Art. VIII, Sec. 7(3))
• Article IV – Disregard for separation of powers via status quo ante order against the House in the Navarro-Gutierrez impeachment
• Article V – Wanton arbitrariness in res judicata issues involving newly created cities and provinces
• Article VI – Unauthorized investigative committee on a Supreme Court Justice, usurping the House’s impeachment power
• Article VII – Partiality granting TROs to President Gloria Macapagal-Arroyo and distortion of Supreme Court rulings
• Article VIII – Failure to account for the Judiciary Development Fund and Special Allowance for the Judiciary
Trial Proceedings and Evidence Rulings
- Petitioner filed an Answer challenging the haste of impeachment, alleged political motives, and denial of due process.
- Prosecution held press conferences disclosing alleged high-value properties and undeclared SALN items; Senate reminded prosecutors of media restrictions under impeachment rules.
- Defense sought preliminary hearing and motions to exclude evidence on paragraphs 2.3 and 2.4 of Article II; both motions denied.
- January 27 resolution: Evidence on nondisclosure (2.2, 2.3) admitted; evidence on ill-gotten wealth (2.4) disallowed, with statutory presumptions under RA 3019 and RA 1379 to guide the Court.
- February 6 resolution: Subpoenas directed to BPI and PSBank officers to produce original bank documents and statements covering multiple accounts and years.
Constitutional and Legal Issues
- Scope of Senate’s subpoena power versus confidentiality under RA 6426 (Foreign Currency Deposits Act).
- Distinction between “culpable violation of the Constitution,” “betrayal of public trust,” and “graft and corruption” as grounds for impeachment.
- Alleged mixture of hearsay, suspicion, and ultimate facts in the impeachment complaint.
- Alleged partiality of Senator-Judges and violation of due process during trial.
- Justiciability of impeachment incidents and the Court’s certiorari power over grave abuse of discretion by political departments.
Contentions of the Parties
Petitioner Argues:
- Impeachment complaint defective for lack of probable cause and due process.
- Senate resolutions admitting and enforcing evidence rulings constitute grave abuse of discretion/excess of jurisdiction.
- Bank subpoenas violate confidentiality of foreign currency deposits under RA 6426.
- Certain Senator-Judges acted as prosecutors, breaching impartiality.
Respondents Argue:
- Impeachment is a political process; issues of verification, procedural irregularities, and trial conduct are nonjusticiable political questions.
- House and Senate possess exclusive constitutional
Case Syllabus (G.R. No. 200242)
Procedural Background
- Petition for certiorari and prohibition with prayer for TRO and preliminary injunction filed by Chief Justice Renato C. Corona
- Impeachment complaint against petitioner verified, endorsed by 188 House members on December 12, 2011 (one-third requirement met)
- Complaint transmitted to Senate December 13, 2011; Senate convened as Impeachment Court December 14, 2011
- Petitioner served copy of Articles of Impeachment December 15, 2011
- Petitioner filed Answer December 26, 2011, denying charges, claiming political bias and procedural infirmities
Articles of Impeachment: Core Allegations
- Article I: Partiality and subservience in cases involving the Arroyo administration and “midnight” appointment
- Article II: Failure to disclose SALN under Art. XI, Sec. 17; alleged omissions of properties and ill-gotten wealth (e.g., 300-sqm Taguig apartment, undisclosed bank deposits)
- Article III: Breach of competence, integrity, probity, independence under Art. VIII, Sec. 7(3) – issuance of flip-flopping decisions, entanglement via wife’s appointment, ex parte discussions
- Article IV: Violation of separation of powers – status quo ante order against the House in Ombudsman Navarro-Gutierrez impeachment
- Article V: Arbitrary disregard of res judicata in creation of 16 new cities and Dinagat Islands province
- Article VI: Usurpation of House’s impeachment investigatory power via self-created committee to probe a Supreme Court Justice
- Article VII: Granting TRO for former President Gloria Macapagal-Arroyo and distortion of Supreme Court’s TRO conditions
- Article VIII: Refusal to account for Judiciary Development Fund and Special Allowance for the Judiciary collections
Senate Trial Proceedings
- Senate as Impeachment Co