3.

CORONA VS SENATE OF THE PHILIPPINES

FACTS:
A verified complaint for impeachment was filed against Chief Justice Renato Corona by respondent
Members of the House of Representatives (HOR). The complaint was transmitted to the Senate which
convened as an impeachment court.
Petitioner Corona received a copy of the complaint charging him with culpable violation of the
Constitution, betrayal of public trust and graft and corruption:
a. when he failed to disclose to the public his statement of assets, liabilities and net worth as
required under Sec. 17, Art. XI of the 1987 Constitution;
b. by failing to meet and observe the stringent standards under Art. VIII, Section 7 (3) of the
Constitution that provides that [a] member of the judiciary must be a person of proven
competence, integrity, probity, and independence in allowing the Supreme Court to act on mere
letters filed by a counsel which caused the issuance of flip-flopping decisions in final and
executory cases;
c.

in creating an excessive entanglement with Mrs. Arroyo through her appointment of his wife to
office; and in discussing with litigants regarding cases pending before the Supreme Court; when
he blatantly disregarded the principle of separation of powers by issuing a status quo ante order
against the HOR in the case concerning the impeachment of then Ombudsman Merceditas
Navarro-Gutierrez;

d. through wanton arbitrariness and partiality in consistently disregarding the principle of res judicata
in the cases involving the 16 newly-created cities, and the promotion of Dinagat Island into a
province;
e. by arrogating unto himself, and to a committee he created, the authority and jurisdiction to
improperly investigate a justice of the Supreme Court for the purpose of exculpating him. Such
authority and jurisdiction is properly reposed by the Constitution in the HOR via impeachment.
f.

through his partiality in granting a temporary restraining order (TRO) in favor of former President
Gloria Macapagal-Arroyo and her husband in order to give them an opportunity to escape
prosecution and to frustrate the ends of justice, and in distorting the Supreme Court decision on
the effectivity of the TRO in view of a clear failure to comply with the conditions of the Supreme
Courts own TRO.

g. when he failed and refused to account for the Judiciary Development Fund (JDF) and Special
Allowance for the Judiciary (SAJ) collections.
The Impeachment Court granted the prosecutions request for subpoena directed to the officers of two
private banks where petitioner allegedly deposited millions in peso and dollar currencies. PSBank filed a
petition for certiorari and prohibition (G.R. No. 200238) seeking to enjoin the Impeachment Court and the
HOR prosecutors from implementing the aforesaid subpoena requiring PSBank thru its authorized
representative to testify and to bring the original and certified true copies of the opening documents for
petitioners alleged foreign currency accounts, and thereafter to render judgment nullifying the subpoenas
including the bank statements showing the year-end balances for the said accounts.
This Court issued a TRO in G.R. No. 200238 enjoining the Senate from implementing the Resolution and
subpoena ad testificandum et duces tecum issued by the Senate sitting as an Impeachment Court, both
dated February 6, 2012. The Court further resolved to deny petitioners motion for the inhibition of

Justices Carpio and Sereno in the absence of any applicable compulsory ground and of any voluntary
inhibition from the Justices concerned.
On the same day, the present petition was filed arguing that the Impeachment Court committed grave
abuse of discretion amounting to lack or excess of jurisdiction when it proceeded to trial on the basis of
the complaint filed by respondent Representatives which complaint is constitutionally infirm and defective
for lack of probable cause. Petitioner filed a Supplemental Petition claiming that his right to due process is
being violated in the ongoing impeachment proceedings because certain Senator-Judges have lost the
cold neutrality of impartial judges by acting as prosecutors. Petitioner particularly mentioned SenatorJudge Franklin S. Drilon, whose inhibition he had sought from the Impeachment Court, to no avail. He
further called attention to the fact that despite the Impeachment Courts January 27, 2012 Resolution
which disallowed the introduction of evidence in support of paragraph 2.4 of Article II, from which no
motion for reconsideration would be entertained, the allies of President Aquino in the Senate abused
their authority and continued their presentation of evidence for the prosecution, without fear of objection.
In view of the persistent efforts of President Aquinos Senator-allies to overturn the ruling of Presiding
Officer Juan Ponce Enrile that the prosecution could not present evidence on paragraph 2.4 of Article II -for which President Aquino even thanked his senator allies in delivering what the prosecution could not-petitioner reiterates the reliefs prayed for in his petition before this Court.
In the Comment Ad Cautelam Ex Superabundanti filed on behalf of the respondents, the Solicitor General
argues that the instant petition raises matters purely political in character which may be decided or
resolved only by the Senate and HOR, with the manifestation that the comment is being filed by the
respondents without submitting themselves to the jurisdiction of the Honorable Supreme Court and
without conceding the constitutional and exclusive power of the House to initiate all cases of
impeachment and of the Senate to try and decide all cases of impeachment. Citing the case of Nixon v.
United States, respondents contend that to allow a public official being impeached to raise before this
Court any and all issues relative to the substance of the impeachment complaint would result in an
unnecessarily long and tedious process that may even go beyond the terms of the Senator-Judges
hearing the impeachment case. Such scenario is clearly not what the Constitution intended.
Respondents maintain that subjecting the ongoing impeachment trial to judicial review defeats the very
essence of impeachment. They contend that the constitutional command of public accountability to
petitioner and his obligation to fully disclose his assets, liabilities and net worth prevail over his claim of
confidentiality of deposits; hence, the subpoena subject of this case were correctly and judiciously issued.
Considering that the ongoing impeachment proceedings, which was initiated and is being conducted in
accordance with the Constitution, simply aims to enforce the principle of public accountability and ensure
that the transgressions of impeachable public officials are corrected, the injury being claimed by petitioner
allegedly resulting from the impeachment trial has no factual and legal basis. It is thus prayed that the
present petition, as well as petitioners prayer for issuance of a TRO/preliminary injunction, be dismissed.

ISSUE:
Whether or not the certiorari jurisdiction of this Court may be invoked to assail matters or incidents arising
from impeachment proceedings, and to obtain injunctive relief for alleged violations of right to due process
of the person being tried by the Senate sitting as Impeachment Court.

RULING:
Impeachment, described as the most formidable weapon in the arsenal of democracy,14 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.15 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 Constitutions 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.
Petitioner likewise assails the Senate in proceeding with the trial under the said complaint, and in the
alleged partiality exhibited by some Senator-Judges who were apparently aiding the prosecution during
the hearings.
On the other hand, respondents contend that the issues raised in the Supplemental Petition regarding the
behavior of certain Senator-Judges in the course of the impeachment trial are issues that do not concern,
or allege any violation of, the three express and exclusive constitutional limitations on the Senates sole
power to try and decide impeachment cases. 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, SenatorJudges 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. But whether the Senate Impeachment Rules were followed
or not, is a political question that is not within this Courts power of expanded judicial review.
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.