GR 237428; (June, 2018) (Digest)
G.R. No. 237428, June 19, 2018
Republic of the Philippines, represented by Solicitor General Jose C. Calida, Petitioner vs. Maria Lourdes P.A. Sereno, Respondent
FACTS
The Supreme Court, in a Decision dated May 11, 2018, granted the Solicitor General’s Petition for Quo Warranto and ousted Maria Lourdes P.A. Sereno as Chief Justice. The Court found her disqualified for lack of proven integrity, primarily due to her failure to file and submit required Statements of Assets, Liabilities, and Net Worth (SALNs) to the Judicial and Bar Council during her application. Respondent Sereno filed an Ad Cautelam Motion for Reconsideration, arguing the Court lacked jurisdiction over an impeachable officer, the petition was time-barred, and she was denied due process. She specifically alleged bias and sought the inhibition of six Justices who concurred in the Decision.
ISSUE
The core issue for reconsideration was whether the Court’s May 11, 2018 Decision should be reversed on grounds of lack of jurisdiction, prescription, or denial of due process, including the alleged bias of the participating Justices.
RULING
The Court denied the Motion for Reconsideration and affirmed its Decision. On jurisdiction, the Court reiterated that quo warranto is a proper remedy to challenge the validity of an appointment based on ineligibility, which is distinct from removal. An ineligible appointee holds no rightful title to the office from the outset; thus, the constitutional bar on removal except by impeachment does not apply. On prescription, the Court ruled the one-year period under the Rules of Court does not strictly apply to the State, and the extraordinary circumstances of the case—where the facts regarding the SALN submissions only recently came to light—justified the petition’s timeliness.
Regarding due process, the Court found Sereno’s claim untenable. She actively participated by filing pleadings, arguing orally, and utilizing media, all while seeking relief from the very Court whose jurisdiction she contested. Her claim of bias against the six Justices was deemed a mere rehash of speculative allegations insufficient to warrant inhibition. The Court emphasized that mere suspicion or imputation is inadequate; clear evidence of arbitrariness is required. The Justices’ prior participation in House committee proceedings as resource persons did not constitute bias or personal knowledge of disputed facts that would disqualify them. The Court concluded that the integrity requirement is a constitutional qualification, and Sereno’s failure to submit the necessary SALNs rendered her ineligible, warranting her ouster via quo warranto.