Case Summary (G.R. No. 200238)
Legal conflict invoked by petitioners
The petition raised the tension between compliance with subpoenas issued by the Impeachment Court and the statutory confidentiality protections afforded to foreign currency deposits under RA 6426. Petitioners contended that complying with the subpoenas would violate RA 6426 and that the Impeachment Court acted improperly or arbitrarily in compelling disclosure despite that confidentiality, thereby prompting the invocation of certiorari and prohibition relief.
Procedural development and motion to withdraw
While the petition was pending, petitioners filed, on November 5, 2012, a motion with leave of court to withdraw the petition. They asserted that subsequent events—most notably the termination of the impeachment proceedings—had removed the immediate conflict that gave rise to the petition: they no longer faced the dilemma of choosing between violating RA 6426 and being held in contempt for refusing to disclose the account details.
Mootness doctrine and its application by the Court
The Court applied the well-established mootness principle that it will not decide questions that have become moot and academic because there is no longer a justiciable controversy. The Court relied on precedent, including Gancho-on (337 Phil. 654, 658 (1997)) and Sales v. Commission on Elections (G.R. No. 174668, Sept. 12, 2007, 533 SCRA 173), to underscore that when an issue has become moot, any declaration would be of no practical use, and courts decline jurisdiction over such matters.
Supervening events rendering the petition moot
The Court found that supervening events had overtaken the central issue. Chief Justice Corona’s conviction on May 29, 2012, and his execution of a waiver of confidentiality over his bank accounts eliminated the factual and legal controversy: the statutory confidentiality protection that formed the basis of petitioners’ refusal was no longer operative as to Corona’s accounts, and the impeachment proceedings had terminated. These developments removed any effective relief the Court could provide and the
...continue readingCase Syllabus (G.R. No. 200238)
Procedural Posture
- Petitioners: Philippine Savings Bank (PSBank) and Pascual M. Garcia III, in his capacity as President of PSBank and in his personal capacity, filed a Petition for Certiorari and Prohibition.
- Relief sought: Nullification and setting aside of a Resolution of the Senate sitting as an Impeachment Court that granted the prosecution's requests for subpoena duces tecum ad testificandum to PSBank and/or its representatives.
- Subject of subpoenas: Testimony and production of documents relative to foreign currency accounts alleged to belong to then Supreme Court Chief Justice Renato C. Corona.
- Subsequent procedural development: On November 5, 2012, during pendency of the petition, petitioners filed a Motion with Leave of Court to Withdraw the Petition, averring supervening events had overtaken the petition and that the dilemma between violating RA 6426 and contempt for refusing to disclose deposit details no longer existed.
- Pending relief at the time of Court action: A temporary restraining order issued by the Court on February 9, 2012.
Parties and Roles
- Petitioners:
- Philippine Savings Bank (PSBank).
- Pascual M. Garcia III, as representative of PSBank and in his personal capacity.
- Respondents:
- The Senate Impeachment Court, consisting of the senators of the Republic of the Philippines acting as senator judges (named senators listed in the source).
- The members of the prosecution panel of the House of Representatives.
- Other persons central to the controversy:
- Then Supreme Court Chief Justice Renato C. Corona, whose foreign currency accounts were the subject of the subpoenas.
Factual Background (as presented)
- The Impeachment Court issued a Resolution granting the prosecution's requests for subpoenas duces tecum ad testificandum directed to PSBank and/or its representatives.
- The subpoenas sought testimony and documents concerning foreign currency accounts alleged to belong to Chief Justice Corona.
- Petitioners claimed a legal dilemma: either violate Republic Act No. 6426 (RA 6426), which protects confidentiality of certain deposits, or be held in contempt for refusing to disclose account details.
- During the pendency of the petition, two supervening events occurred:
- The conviction of Chief Justice Renato C. Corona on May 29, 2012.
- Chief Justice Corona executed a waiver against the confidentiality of all his bank accounts, whether in peso or foreign currency.
- Based on these events, petitioners moved to withdraw their petition, asserting the controversy had been overtaken by events.
Legal Relief Sought and Basis of Petition
- Petition for Certiorari and Prohibition:
- Sought to nullify and set aside the Impeachment Court’s Resolution that compelled PSBank to testify and produce documents.
- Challenged the issuance of subpoenas insofar as they sought information allegedly protected by RA 6426 (confidentiality of foreign currency deposits).
- Underpinning legal concern:
- Whether the Impeachment Court acted arbitrarily in issuing subpoenas to obtain information regarding foreign currency deposits despite statutory confidentiality protections.
Legal Issue(s) Presented
- Primary legal issue explicitly presented in