G.R. No. 237428, June 19, 2018
Republic of the Philippines, represented by the Office of the Solicitor General vs. Maria Lourdes P.A. Sereno

FACTS

The Supreme Court, in a Decision dated May 11, 2018, granted the Petition for Quo Warranto filed by the Republic against Chief Justice Maria Lourdes Sereno. The Court found her disqualified from office for failure to submit the required number of Statements of Assets, Liabilities and Net Worth (SALNs) to the Judicial and Bar Council during her application, thereby failing to prove her integrity. The dispositive portion ousted Sereno from the position and declared the office of the Chief Justice vacant. Subsequently, Sereno filed an Ad Cautelam Motion for Reconsideration, which included a plea for the reconsideration of the denial of her earlier motions for the inhibition of six Associate Justices, including Justice Leonardo-De Castro.
In her motion, Sereno argued that these Justices, particularly Justice De Castro, should have recused themselves due to evident bias and partiality. She specifically pointed to Justice De Castro’s testimony as a resource person before the House Committee on Justice during the impeachment proceedings against her. Sereno contended that this participation demonstrated pre-judgment and a lack of impartiality necessary for adjudicating the related quo warranto petition.

ISSUE

Whether Justice Leonardo-De Castro, and by implication the other named Justices, committed grave abuse of discretion in not inhibiting themselves from participating in the quo warranto proceedings against Chief Justice Sereno.

RULING

The Court, through Justice De Castro’s separate concurring opinion, denied the motion for inhibition as without factual or legal basis. The legal logic is clear: testifying as a resource person before a co-equal branch of government on matters within one’s official and personal knowledge does not, by itself, constitute bias or a ground for mandatory inhibition. Justice De Castro emphasized that her testimony before the House Committee was objective, factual, and limited to specific administrative matters and adjudication issues raised in the impeachment complaint, such as the alleged creation of the Judiciary Decentralized Office and manipulations within the Judicial and Bar Council. Crucially, she had no personal knowledge of the central factual issue in the quo warranto petition—Sereno’s failure to submit her SALNs to the JBC. This fact was only uncovered years later. Her testimony was an act of deference to a congressional inquiry, authorized by the Court en banc, and was not motivated by personal animosity. Therefore, no evidence of prejudice or partiality existed that would disqualify her from hearing the case. The denial of the motion for reconsideration, including the plea for inhibition, was upheld.