G.R. No. A.M. No. 12-6-10-SC; June 13, 2012
RE: COMPLAINT AGAINST THE HON. CHIEF JUSTICE RENATO C. CORONA DATED SEPTEMBER 14, 2011 FILED BY INTER-PETAL RECREATIONAL CORPORATION

FACTS

This administrative matter originated from a complaint filed by Inter-Petal Recreational Corporation against then Chief Justice Renato C. Corona on September 14, 2011. The specific allegations contained in this complaint are not detailed in the resolution but formed the basis for a separate administrative proceeding before the Supreme Court. While this administrative complaint was pending, Chief Justice Corona was simultaneously undergoing impeachment proceedings before the Senate, sitting as an Impeachment Court, based on Articles of Impeachment filed by the House of Representatives.
The impeachment trial culminated in a Judgment dated May 29, 2012, where the Senate Impeachment Court found Chief Justice Corona guilty of the charge under Article II of the Articles of Impeachment. The Senate imposed the constitutional penalty of removal from office and disqualification from holding any future office under the Republic of the Philippines. This judgment was rendered prior to the Supreme Court’s final resolution of the separate administrative complaint filed by Inter-Petal Recreational Corporation.

ISSUE

Whether the pending administrative complaint against Chief Justice Renato C. Corona should proceed given his prior removal from office via impeachment.

RULING

The Supreme Court En Banc dismissed the administrative complaint for being moot and academic. The legal logic is anchored on the final and executory effect of the Senate’s impeachment judgment. The Senate, acting as the sole Impeachment Court under the Constitution, had already rendered a verdict finding Corona guilty and meting out the penalty of removal and disqualification. This penalty is the most severe constitutional sanction for an impeachable officer and was fully executed upon the promulgation of the judgment.
Consequently, any further administrative proceedings against Corona concerning his fitness to hold the office of Chief Justice lost their practical legal purpose. The primary objective of an administrative case against a sitting official is to determine their culpability and impose appropriate sanctions, which may include removal. Since the impeachment process, a separate constitutional mechanism, had already achieved that ultimate result with finality, continuing the administrative case would serve no practical end. The Court applied the well-settled doctrine that courts will not determine moot questions or abstract propositions, as their duty is to decide actual controversies affecting the legal rights of litigants. With Corona already removed and disqualified by a competent tribunal, the administrative complaint presented no live grievance requiring adjudication and was therefore correctly dismissed.