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

Case Summary (G.R. No. 200242)

Factual Background

The House Committee on Justice presented a verified complaint for impeachment allegedly supported by a caucus of the House majority on December 12, 2011, and 188 Members of the House signed and endorsed the complaint. The complaint charged petitioner with betrayal of public trust, culpable violation of the Constitution, and graft and corruption, with multiple articles alleging among other things failure to disclose property and bank accounts in his SALN, partiality in cases involving the Arroyo administration, issuance of a status quo ante order concerning an impeachment of an Ombudsman, disregard of res judicata in local government cases, unauthorized investigations of a Supreme Court Justice, grant of a TRO favorable to former President Gloria Macapagal-Arroyo, and failure to account for the Judiciary Development Fund and Special Allowance for the Judiciary.

Articles of Impeachment

Article II of the articles focused on petitioner's alleged failure to disclose his Statement of Assets, Liabilities and Net Worth (SALN) as required by Art. XI, Sec. 17, 1987 Constitution, and asserted in separate paragraphs that some properties were omitted from the SALN, that petitioner accumulated ill-gotten wealth and maintained bank accounts with huge deposits, and that he owned a 300-square-meter apartment in a Megaworld property in Fort Bonifacio. Other articles alleged judicial partiality, breach of separation of powers, res judicata violations, improper investigatory authority, and failure to account for judicial funds.

Proceedings in the House and Senate

The House transmitted the complaint to the Senate on December 13, 2011, and the Senate convened as an Impeachment Court. The Impeachment Court began hearings on January 16, 2012. The prosecution publicly disclosed alleged documentary and property evidence to the media; the Senate warned prosecutors about media disclosures under its impeachment rules. The Impeachment Court admitted certain evidence and, by its January 27, 2012 Resolution, allowed the prosecution to introduce evidence in support of paragraphs 2.2 and 2.3 of Article II, but disallowed evidence under paragraph 2.4 while indicating reliance on legal presumptions under Republic Act No. 3019 and Republic Act No. 1379. By Resolution dated February 6, 2012, the Impeachment Court granted subpoenas ad testificandum et duces tecum to officers of PSBank and BPI to produce account-opening documents and year-end balances for specified accounts.

Petitioner’s Claims and Reliefs Sought

Petitioner filed an Answer on December 26, 2011, and thereafter lodged a petition with this Court on February 8, 2012, asserting that the impeachment complaint and the Senate trial suffered from constitutional infirmities and grave abuse of discretion. He contended that the complaint was adopted in a "blitzkrieg" manner without probable cause, that Article II comprised hearsay and suspicions rather than ultimate facts, that the Impeachment Court erred in allowing evidence under paragraphs 2.2 and 2.3 which could be used to prove paragraph 2.4, that presentation of alleged bank accounts violated confidentiality under R.A. No. 6426, and that several Senator-Judges displayed partiality. Petitioner sought injunctive relief to enjoin the impeachment proceedings, to prohibit enforcement of the February 6, 2012 Resolution and subpoenas, to bar the presentation of evidence on paragraphs 2.3 and 2.4, and ultimately to declare the impeachment complaint void ab initio.

Respondents’ Contentions

The Solicitor General and the House prosecutors filed a Comment ad cautelam asserting that the matters raised were political in nature and that the House and the Senate possess the constitutional authority exclusively to initiate and try impeachment cases. Respondents invoked the principle that permitting comprehensive judicial review of impeachment proceedings would frustrate the constitutional design and cite Nixon v. United States, 506 U.S. 224 (1993) as persuasive authority. They argued that the Impeachment Court had not gravely abused its discretion, that public accountability and the constitutional duty to disclose SALNs outweighed claims of bank-deposit confidentiality, and that the subpoenas and impeachment process were properly issued and pursued.

Procedural History in this Court

Multiple petitions seeking injunctive relief were filed with this Court; an earlier TRO in G.R. No. 200238 enjoined the Senate from implementing the bank subpoena in respect of PSBank. Petitioner also sought the inhibition of Justices Carpio and Sereno, which this Court denied in the absence of a compulsory ground. The present petition proceeded to the En Banc Court for resolution.

Legal Issues Presented

The petition raised whether this Court’s certiorari jurisdiction could reach procedural incidents of an impeachment trial, whether the complaint met constitutional requisites of ultimate facts and probable cause, whether the Impeachment Court abused its discretion in allowing certain evidence and issuing bank subpoenas in alleged violation of R.A. No. 6426, and whether alleged partiality by Senator-Judges rendered the trial violative of due process.

The Court’s Discussion on Judicial Review of Impeachment

The Court reviewed the nature of impeachment as a constitutional mechanism and recognized the political character of impeachment proceedings while reaffirming that acts of any branch are subject to judicial review when tainted by grave abuse, arbitrariness or lack or excess of jurisdiction. The Court cited its prior holdings that justiciable issues arising from impeachment proceedings may be reviewed—specifically Francisco, Jr. v. Nagmamalasakit na mga Manananggol ng mga Manggagawang Pilipino, Inc., G.R. Nos. 160261, November 10, 2003, 415 SCRA 44, and Gutierrez v. House of Representatives Committee on Justice, G.R. No.193459, February 15, 2011, 643 SCRA 199—to establish that expanded judicial review exists in this jurisdiction for justiciable constitutional issues.

Mootness and Supervening Events

The Court observed that the impeachment trial was completed and that petitioner was convicted by the requisite Senate vote. Petitioner accepted the Senate’s verdict and vacated his office, and the Judicial and Bar Council proceeded to screen successors with exe

Case Syllabus (G.R. No. 200242)

Parties

CHIEF JUSTICE RENATO C. CORONA, PETITIONER filed a petition for certiorari and prohibition with prayer for temporary restraining order and writ of preliminary injunction.
SENATE OF THE PHILIPPINES SITTING AS AN IMPEACHMENT COURT, RESPONDENT was the tribunal conducting the impeachment trial against petitioner.
BANK OF THE PHILIPPINE ISLANDS and PHILIPPINE SAVINGS BANK were subpoenaed to produce bank account documents and to testify.
NIEL TUPAS, JR., NERI COLMENARES, and other named Representatives were the prosecutors from the House of Representatives and named respondents in the petition.

Procedural Posture

The House of Representatives transmitted a verified complaint for impeachment to the Senate after a December 12, 2011 caucus and the complaint was endorsed by 188 Members.
The Senate convened as an Impeachment Court and commenced the trial on January 16, 2012.
Petitioner filed the present petition challenging the impeachment proceedings and requesting injunctive relief before this Court.
The Impeachment Court issued resolutions on January 27, 2012 and February 6, 2012 permitting certain evidence and issuing subpoenas to banks.
The Court subsequently dismissed the petition on the ground of mootness after petitioner was convicted in the impeachment trial and vacated office.

Key Facts

The verified complaint was transmitted to petitioner on December 15, 2011 and charged him with multiple articles of impeachment.
The prosecution publicly disclosed allegations of unreported high-value properties and alleged undeclared bank accounts, prompting media reporting and public comment.
In compliance with a subpoena, this Court's Clerk of Court produced petitioner's SALNs for 2002 to 2010 before the Impeachment Court.
The Impeachment Court allowed the prosecution to present evidence on certain SALN-related allegations and granted subpoenas to BPI and PSBank for account opening documents and year-end balances.
Petitioner sought inhibition of Justices Antonio T. Carpio and Maria Lourdes P. A. Sereno and later asserted partiality by Senator-Judge Franklin S. Drilon.

Articles of Impeachment

Article I alleged betrayal of public trust through partiality and subservience in cases involving the Arroyo administration and in the appointment as Chief Justice.
Article II alleged culpable violation of the Constitution and failure to disclose his Statement of Assets, Liabilities and Net Worth pursuant to Art. XI, Sec. 17, 1987 Constitution, and alleged unexplained acquisitions and bank accounts.
Article III alleged failure to meet standards of competence, integrity, probity, and independence under Art. VIII, Section 7 (3).
Articles IV through VIII alleged violations including disregard of separation of powers, wanton arbitrariness regarding res judicata, improper internal investigations, partiality in issuing TROs favoring former President Gloria Macapagal-Arroyo, and failure to account for the Judiciary Development Fund and Special Allowance for the Judiciary.

Petitioner's Contentions

Petitioner contended that the impeachment complaint was signed and transmitted in a blitzkrieg fashion and lacked probable cause.
Petitioner argued that paragraphs alleging SALN omissions and unexplained wealth were premised on suspicion and hearsay and failed to state ultimate facts.
Petitioner asserted that admission of alleged bank evidence violated confidentiality under R.A. No. 6426 and Section 10 thereof and was therefore inadmissible as fruit of an illegal act.
Petitioner sought injunctive relief enjoining the