G.R. No. 200238 , November 20, 2012
PHILIPPINE SAVINGS BANK (PSBANK) and PASCUAL M. GARCIA III vs. SENATE IMPEACHMENT COURT, et al.

FACTS

Petitioners Philippine Savings Bank (PSBank) and its President, Pascual M. Garcia III, filed a Petition for Certiorari and Prohibition. They sought to nullify a Resolution issued by the respondent Senate, acting as an Impeachment Court, which granted the prosecution panel’s request for subpoena duces tecum ad testificandum. The subpoena required PSBank and its representatives to testify and produce documents before the impeachment court concerning foreign currency deposit accounts alleged to belong to then Supreme Court Chief Justice Renato C. Corona. The petitioners contended that complying with the subpoena would force them to violate Republic Act No. 6426 , or the Foreign Currency Deposit Act, which mandates the absolute confidentiality of foreign currency deposits.
During the pendency of this petition before the Supreme Court, the petitioners filed a Motion with Leave of Court to Withdraw the Petition. They averred that subsequent events had overtaken the petition, rendering it unnecessary. Specifically, they cited the termination of the impeachment proceedings against former Chief Justice Corona, which removed the imminent dilemma of choosing between violating the bank secrecy law or facing contempt charges from the impeachment court for non-compliance with the subpoena.

ISSUE

Whether the Supreme Court should rule on the merits of the petition challenging the impeachment court’s subpoena for confidential foreign currency deposit records.

RULING

The Supreme Court dismissed the petition for having become moot and academic. The Court’s ruling is anchored on the well-settled judicial policy of refusing to adjudicate moot cases. A case becomes moot when there is no longer an actual, live controversy between the parties, and any judicial determination would serve no practical legal purpose or provide any substantial relief. The Court cited precedent, including Gancho-on v. Secretary of Labor and Employment, which holds that courts decline jurisdiction over moot questions where no actual interests are involved.
The legal logic applied is that the supervening events had extinguished the justiciable controversy that initially prompted the petition. The impeachment trial of Chief Justice Corona concluded with his conviction on May 29, 2012. Furthermore, Chief Justice Corona himself had executed a waiver against the confidentiality of all his bank accounts. Consequently, the core issue—whether the Impeachment Court acted arbitrarily in issuing the subpoena despite the confidentiality provisions of R.A. No. 6426 —was overtaken by these events. With the impeachment proceedings terminated and the account holder’s waiver in place, the petitioners were no longer faced with the legal dilemma that necessitated judicial intervention. Therefore, granting legal relief was neither needed nor called for. The Court lifted the temporary restraining order it had previously issued and abstained from making a ruling on the substantive merits of the case.