GR 200242; (July, 2012) (Digest)
G.R. No. 200242 ; July 17, 2012
CHIEF JUSTICE RENATO C. CORONA, Petitioner, vs. SENATE OF THE PHILIPPINES sitting as an IMPEACHMENT COURT, et al., Respondents.
FACTS
On December 12, 2011, the House of Representatives, in a caucus of its majority bloc, initiated an impeachment complaint against Chief Justice Renato C. Corona. The complaint, endorsed and signed by 188 members, was transmitted to the Senate on December 13, 2011. The Senate convened as an impeachment court and commenced trial. The Articles of Impeachment charged petitioner with culpable violation of the Constitution, betrayal of public trust, and graft and corruption, citing various alleged acts including failure to publicly disclose his Statement of Assets, Liabilities and Net Worth (SALN), partiality in Supreme Court decisions, and improper handling of judiciary funds.
Petitioner filed a petition for certiorari and prohibition with the Supreme Court, assailing the impeachment proceedings. He argued that the impeachment complaint was invalidly adopted through a “blitzkrieg” process that violated the House’s own rules of procedure, thereby depriving the Senate of jurisdiction to try him. He sought to enjoin the Senate from proceeding with the trial. However, while the petition was pending, the impeachment trial concluded, resulting in petitioner’s conviction by the Senate on May 29, 2012. Petitioner accepted the verdict and vacated his office.
ISSUE
Whether the petition for certiorari and prohibition assailing the impeachment proceedings has been rendered moot and academic by the supervening conviction of the petitioner and his vacation of office.
RULING
Yes, the petition is dismissed on the ground of mootness. The Court held that the constitutional issue raised by petitioner had been overtaken by supervening events, specifically the conclusion of the impeachment trial, his conviction by the required majority vote of the Senator-Judges, and his subsequent acceptance of the verdict and vacation of the office of Chief Justice. An issue becomes moot and academic when it ceases to present a justiciable controversy, such that a judicial determination would no longer provide any actual and substantial relief to the parties. In this case, a ruling from the Supreme Court on the procedural validity of the impeachment complaint’s initiation would be of no practical legal value or effect. The impeachment process had reached its final constitutional outcome, and petitioner was no longer in office. The Court therefore refrained from making a pronouncement on the substantive merits of the petition, as no effective remedy could be granted. The dismissal on the ground of mootness is consistent with the judicial policy of avoiding advisory opinions on abstract or hypothetical questions.