View full case

PHILIPPINE SAVINGS BANK

FACTS:

The petitioners, Philippine Savings Bank (PSBank) and Pascual M. Garcia III, filed a petition seeking to nullify and set aside the resolution of the Senate of the Republic of the Philippines, sitting as an Impeachment Court, which granted the prosecution's requests for subpoenas duces tecum ad testificandum to PSBank and/or its representatives. The subpoenas required PSBank to testify and produce documents relative to foreign currency accounts allegedly belonging to then Supreme Court Chief Justice Renato C. Corona. During the pendency of the petition, the petitioners filed a motion to withdraw the petition, citing that subsequent events have overtaken the case and there is no longer any dilemma as the impeachment proceedings against Chief Justice Corona have terminated. They also emphasized that they no longer need to disclose the details of the subject foreign currency deposits as Chief Justice Corona executed a waiver against the confidentiality of all his bank accounts. The court held that the issue raised in the petition has become moot and academic due to the supervening conviction of Chief Justice Corona and his execution of a waiver against the confidentiality of his bank accounts. Thus, the court dismissed the petition and lifted the temporary restraining order.

ISSUES:

  1. Whether the petition has become moot and academic

  2. Whether the Court should pass upon the merits of the case

RULING:

  1. Yes, the issue has become moot and academic. The supervening conviction of Chief Justice Corona and his execution of a waiver against the confidentiality of all his bank accounts has rendered the petition moot and academic.

  2. No, the Court should abstain from passing upon the merits of the case where legal relief is no longer needed nor called for.

PRINCIPLES:

  • Courts will not determine questions that have become moot and academic because there is no longer any justiciable controversy to speak of.

  • Where the issue has become moot and academic, there is no justiciable controversy, and a declaration thereon would be of no practical use or value.

  • The Court will abstain from passing upon the merits of a case where legal relief is no longer needed nor called for.