Case Summary (G.R. No. 237428)
Petition and Dispositive Decision
May 11, 2018 Decision: Grant of quo warranto petition declaring respondent disqualified for having unlawfully held and exercised the office of Chief Justice. Respondent was ousted and the JBC ordered to fill the vacancy. Show-cause order issued for possible professional sanctions.
Motion for Reconsideration: Grounds Advanced
Respondent’s ad cautelam motion argues:
- Denial of due process – tribunal allegedly partial and biased; improper reception of extraneous evidence; failure to observe evidence rules.
- Lack of jurisdiction – Chief Justice removable only by impeachment; petition time-barred.
- Executive and JBC acts involve political questions and not subject to quo warranto absent grave abuse of discretion.
- Respondent’s integrity proven and JBC standards should govern.
Denial of Due Process and Alleged Partiality
– Respondent was heard at every stage and availed of comments, memoranda, oral argument and show-cause.
– Mere allegations of bias against the six Justices – or that they had personal knowledge or served as witnesses – were unsubstantiated and previously resolved.
– Reference to draft footnotes, JBC inquiries, or public records did not circumvent due process; all materials were properly before the Court.
– No acts or conduct indicative of arbitrariness or prejudice were shown to require inhibition.
Jurisdiction Over Impeachable Officers by Quo Warranto
– 1987 Constitution, Article VIII, Section 5 grants original jurisdiction over quo warranto without excluding impeachable officers.
– Precedent (Sarmiento v. Mison; Estrada v. Macapagal-Arroyo) confirms quo warranto inquiry into eligibility and title even for impeachable officials.
– Quo warranto determines qualification and title (“ouster”), distinct from impeachment (“removal” for impeachable offenses).
– Article VII, Section 4(7) furthers the Court’s role as sole judge of the President’s and Vice-President’s qualifications; analogously extends to other public officers.
– Impeachment grounds do not cover lack of constitutional qualifications (age, citizenship, integrity); quo warranto fills that gap.
Prescriptive Period and Public Interest Exception
– Rule 66, Section 11 prescribes a one-year period for quo warranto by private individuals.
– The State’s petition by the Solicitor General is not subject to prescription because the State cannot waive enforcement of constitutional requirements.
– Public interest in securing only qualified officeholders outweighs limitation considerations; delay by the State is not imputable as laches or waiver.
SALN Non-Filing and Respondent’s Integrity
– Certifications from the UP Human Resources Department and the Office of the Ombudsman establish respondent’s failure to file SALNs for several years prior to appointment.
– These official cer
Case Syllabus (G.R. No. 237428)
Background
- Petitioner: Republic of the Philippines, represented by Solicitor General Jose C. Calida.
- Respondent: Maria Lourdes P. A. Sereno, then sitting Chief Justice of the Supreme Court.
- May 11, 2018 Decision: Granted quo warranto petition, ruled respondent disqualified for unlawfully holding and exercising her office, ousted her, declared vacancy, and ordered show‐cause for possible sanctions.
- Motions before the Court En Banc:
• Ad Cautelam Motion for Reconsideration of the May 11 Decision.
• Ad Cautelam Motion for Extension of Time to File Reply to Show Cause Order.
Procedural History
- Quo warranto petition filed March 2, 2018 by OSG challenging respondent’s eligibility to be Chief Justice.
- May 11, 2018 Decision striking respondent’s title and declaring the post vacant.
- Respondent’s showing of cause order and her two ad cautelam motions.
- OSG’s Comment urging denial of respondent’s motions as pro forma and lacking merit.
Respondent’s Contentions
- Due process violation: alleged tribunal partiality, failure to observe evidence procedures, reliance on extraneous matters.
- Jurisdictional objections: only Congress may remove impeachable officers by impeachment; quo warranto improper and time‐barred; political questions on JBC and Presidential acts.
- Integrity defense: respondent is of proven integrity; non‐filing of SALNs irrelevant or justified.
OSG’s Arguments
- No due process breach: respondent was heard, filed pleadings, argued merits in various forums.
- Quo warranto proper remedy for unqualified impeachable officer; impeachment and quo warranto are distinct.
- No bias warranting inhibition; mere speculation insufficient.
- State exception to one‐year prescription for quo warranto; public interest precludes laches.
- Respondent’s failure to file SALNs for multiple years undermines her “proven integrity.”
Due Process and Impartial Tribunal
- Allegations of actual bias against six Ju