M-Xii Corona vs. Senate

CHIEF JUSTICE RENATO C. CORONA vs.
SENATE OF THE PHILIPPINES
G.R. No. 200242 July 17, 2012
DOCTRINE: Impeachment refers to the power of Congress to remove a public official for serious
crimes or misconduct as provided in the Constitution. A mechanism designed to check abuse of
power. Impeachment case is a matter of utmost importance to ensure the effective functioning of
the separate branches while preserving the structure of checks and balance in our government.
Moreover, in this jurisdiction, the acts of any branch or instrumentality of the government,
including those traditionally entrusted to the political departments, are proper subjects of judicial
review if tainted with grave abuse or arbitrariness.
FACTS: On December 12, 2011, a caucus was held by the majority bloc of the HOR during
which a verified complaint for impeachment against then petitioner CJ Corona was submitted by
the leadership of the Committee on Justice. After a brief presentation, on the same day, the
complaint was voted in session and 188 Members signed and endorsed it, way above the one-
third vote required by the Constitution.The next day, the complaint was transmitted to the Senate
which convened as an impeachment court the following day.
On December 15, 2011, petitioner received a copy of the complaint charging him with culpable
violation of the Constitution, betrayal of public trust and graft and corruption. (numerous and long
enumerations sa full text hihihi) but some of their allegations are; CJ Corona’s failure to report
some properties in his SALN and the acquisition of ill-gotten wealth and failure to disclose in
SALN such bank accounts with huge deposits and 300-sq.m. Mega world property at the Fort in
Taguig hence, they alleged failure to disclose to the public his SALN as required by the
Constitution) and some issues of partiality and incompetence as a Chief justice.
On December 26, 2011, petitioner filed his Answer assailing the "blitzkrieg" fashion by which the
impeachment complaint was signed by the Members of the HOR and immediately transmitted to
the Senate. Citing previous instances when President Aquino openly expressed his rejection of
petitioner’s appointment as Chief Justice and publicly attacked this Court under the leadership of
petitioner for "derailing his administration’s mandate," petitioner concluded that the move to
impeach him was the handiwork of President Aquino’s party mates and supporters, including "
hidden forces" who will be benefited by his ouster.
As to the charges against him, petitioner denied the same but admitted having once served the
Offices of the President and Vice-President during the term of former PGMA. Petitioner argued at
length that the acts, misdeeds or offenses imputed to him were either false or baseless, and
otherwise not illegal nor improper. He prayed for the outright dismissal of the complaint for failing
to meet the requirements of the Constitution or that the Impeachment Court enter a judgment of
acquittal for all the articles of impeachment.
Petitioner also sought the inhibition of Justices Antonio T. Carpio and Maria Lourdes P. A.
Sereno on the ground of partiality, citing their publicly known "animosity" towards petitioner
aside from the fact that they have been openly touted as the likely replacements in the event
that petitioner is removed from office.
Petitioner likewise assails the Senate partiality exhibited by some Senator-Judges during the
impeachment proceeding who were apparently aiding the prosecution during the hearings.
But they argue that unless there is a clear transgression of these constitutional limitations,
this Court may not exercise its power of expanded judicial review over the actions of
Senator-Judges during the proceedings.
By the nature of the functions they discharge when sitting as an Impeachment Court,
Senator- Judges are clearly entitled to propound questions on the witnesses, prosecutors
and counsel during the trial. Petitioner thus failed to prove any semblance of partiality on the
part of any Senator-Judges.
ISSUE: On the basis of these precedents, petitioner asks this Court to determine whether
respondents committed a violation of the Constitution or gravely abused its discretion in the
exercise of their functions and prerogatives that could translate as lack or excess of jurisdiction,
which would require corrective measures from the Court.
HELD: NO. Impeachment, described as "the most formidable weapon in the arsenal of
democracy," was foreseen as creating divisions, partialities and enmities, or highlighting pre-
existing factions with the greatest danger that "the decision will be regulated more by the
comparative strength of parties, than by the real demonstrations of innocence or guilt." Given
their concededly political character, the precise role of the judiciary in impeachment cases is a
matter of utmost importance to ensure the effective functioning of the separate branches while
preserving the structure of checks and balance in our government. Moreover, in this jurisdiction,
the acts of any branch or instrumentality of the government, including those traditionally
entrusted to the political departments, are proper subjects of judicial review if tainted with grave
abuse or arbitrariness.
Impeachment refers to the power of Congress to remove a public official for serious crimes or
misconduct as provided in the Constitution. A mechanism designed to check abuse of power,
impeachment has its roots in Athens and was adopted in the United States (US) through the
influence of English common law on the Framers of the US Constitution.
Our own Constitution’s provisions on impeachment were adopted from the US Constitution.
Petitioner was impeached through the mode provided under Art. XI, par. 4, Sec. 3, in a manner
that he claims was accomplished with undue haste and under a complaint which is defective for
lack of probable cause.
In the meantime, the impeachment trial had been concluded with the conviction of petitioner by
more than the required majority vote of the Senator-Judges. Petitioner immediately accepted the
verdict and without any protest vacated his office. In fact, the Judicial and Bar Council is already
in the process of screening applicants and nominees, and the President of the Philippines is
expected to appoint a new Chief Justice within the prescribed 90-day period from among those
candidates shortlisted by the JBC. Unarguably, the constitutional issue raised by petitioner had
been mooted by supervening events and his own acts.
An issue or a case becomes moot and academic when it ceases to present a justiciable
controversy so that a determination thereof would be without practical use and value. In such
cases, there is no actual substantial relief to which the petitioner would be entitled to and which
would be negated by the dismissal of the petition. WHEREFORE, the present petition for
certiorari and prohibition with prayer for injunctive relief/s is DISMISSED on the ground of
MOOTNESS.

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CHIEF JUSTICE RENATO C. CORONA vs.

SENATE OF THE PHILIPPINES

G.R. No. 200242 July 17, 2012

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