View full case

CHIEF JUSTICE RENATO C. CORONA v. SENATE AS IMPEACHMENT COURT

FACTS:

The case involves Chief Justice Corona's petition challenging the impeachment case initiated by the Members of the House of Representatives (HOR) and the trial being conducted by the Senate of the Philippines. On December 12, 2011, a verified complaint for impeachment against Corona was submitted and endorsed by 188 Members of the HOR. The complaint charged Corona with culpable violation of the Constitution, betrayal of public trust, and graft and corruption. It accused Corona of various acts, including showing partiality, failing to disclose his assets, violating separation of powers, disregarding res judicata, and improperly investigating a justice of the Supreme Court. On December 26, 2011, Corona filed his Answer, challenging the manner in which the impeachment complaint was signed and transmitted.

In the impeachment trial, the prosecution panel held a press conference publicly revealing evidence against Corona. The media reported on high-priced properties allegedly not included in his Statement of Assets, Liabilities, and Net Worth (SALN). Five petitions were filed before the Supreme Court seeking to stop the impeachment trial. The Impeachment Court denied Corona's motion for a preliminary hearing and continued with the trial. The Clerk of Court submitted Corona's SALNs for the years 2002 to 2010, and prosecution witnesses testified about alleged failures to report properties in them. The Impeachment Court allowed the prosecution to introduce evidence supporting certain allegations and granted subpoenas to two private banks where Corona allegedly deposited large sums of money.

ISSUES:

  1. Whether the Impeachment Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in proceeding to trial based on a complaint that lacked probable cause and contained multiple charges premised on suspicion and hearsay.

  2. Whether the Impeachment Court violated the petitioner's right to due process by allowing the presentation of evidence on charges of alleged corruption and unexplained wealth, which are not specifically mentioned as grounds for impeachment.

  3. Whether the issuance of subpoenas for the production of the petitioner's alleged bank accounts violated the absolute confidentiality of such accounts and the Foreign Currency Deposits Act.

  4. Whether the certiorari jurisdiction of the Supreme Court may be invoked to challenge matters arising from impeachment proceedings and to obtain injunctive relief for alleged violations of due process.

  5. Whether the ongoing impeachment trial violates the petitioner's right to due process due to the alleged partiality of certain Senator-Judges.

  6. Whether the behavior of certain Senator-Judges in the impeachment trial are issues that fall within the three express and exclusive constitutional limitations on the Senate's power to try and decide impeachment cases.

  7. Whether the Senate Impeachment Rules were followed or not.

  8. Whether the Court has the power to exercise expanded judicial review over the actions of Senator-Judges during impeachment proceedings.

RULING:

  1. The Court issued a temporary restraining order (TRO), enjoining the Senate from implementing the Resolution and subpoena ad testificandum et duces tecum.

  2. The Supreme Court held that it does not have jurisdiction to entertain certiorari petitions or issue injunctive relief regarding impeachment proceedings. Impeachment is a political process and the role of the judiciary in impeachment cases is limited. The Court cannot interfere with the proceedings or decisions of an impeachment court unless there is a clear showing of grave abuse of discretion. The impeachment trial does not violate the petitioner's right to due process as long as the proceedings are conducted judiciously and in accordance with the Constitution.

  3. The Court held that the behavior of certain Senator-Judges in the impeachment trial did not concern or allege any violation of the three express and exclusive constitutional limitations on the Senate's power to try and decide impeachment cases. The Court also found that the petitioner failed to prove any semblance of partiality on the part of any Senator-Judges.

  4. The Court held that whether the Senate Impeachment Rules were followed or not is a political question that is not within the Court's power of expanded judicial review.

  5. The Court dismissed the petition on the ground of mootness, stating that the impeachment trial had been concluded and the petitioner had accepted the verdict and vacated his office. The Court explained that an issue becomes moot and academic when it ceases to present a justiciable controversy and there is no actual substantial relief to which the petitioner would be entitled.

PRINCIPLES:

  • The Impeachment Court must base its proceedings on a complaint that contains probable cause.

  • The right to due process requires that charges in an impeachment complaint be specific and must adhere to the grounds for impeachment specified in the Constitution.

  • Bank accounts enjoy absolute confidentiality, and the production of bank records may violate the law on the confidentiality of foreign currency deposits.

  • Impeachment is a political process designed to check abuse of power. The role of the judiciary in impeachment cases is limited.

  • Impeachment proceedings and decisions are generally not subject to judicial review, unless there is a clear showing of grave abuse of discretion.

  • 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.

  • The power of judicial review in the Philippines includes the power to review justiciable issues in impeachment proceedings.

  • A case becomes moot and academic when it ceases to present a justiciable controversy, and a determination thereof would be without practical use and value.