GR 237428 So; (May, 2018) (Digest)
G.R. No. 237428, May 11, 2018
Republic of the Philippines, represented by the Office of the Solicitor General vs. Maria Lourdes P. A. Sereno
FACTS
The Republic, through the Office of the Solicitor General, filed a petition for quo warranto seeking to oust Chief Justice Maria Lourdes Sereno. The petition alleged that her appointment was invalid due to a lack of proven integrity, a constitutional requirement for members of the Judiciary. The specific ground was her alleged failure to comply with the mandatory filing of her Statements of Assets, Liabilities, and Net Worth (SALNs) during her tenure as a professor at the University of the Philippines College of Law. When applying for the position of Chief Justice in 2012, the Judicial and Bar Council required the submission of all previous SALNs. Respondent submitted only her SALNs for 2009, 2010, and 2011. A certification from UP indicated that, for the period 2000 to 2009, only her 2002 SALN was on file.
ISSUE
The principal issue was whether a quo warranto proceeding is the proper remedy to challenge the appointment of an impeachable officer, specifically the Chief Justice, on grounds of alleged lack of integrity due to non-compliance with SALN filing requirements.
RULING
The Court, in its Decision, granted the quo warranto petition and declared the appointment of respondent as Chief Justice null and void. The legal logic proceeded from the premise that the requirement of proven integrity under Section 7(3), Article VIII of the Constitution is a continuing qualification. A quo warranto proceeding is available to question the validity of an appointment if the appointee is alleged to be ineligible from the start, as the right to hold office must be vested at the time of appointment. The Court ruled that respondent’s repeated failure to file her SALNs, as required by the Constitution, Republic Act No. 3019, and Republic Act No. 6713, constituted a failure to show the requisite integrity for the office. This failure to submit the required SALNs to the JBC meant she was not qualified at the time of her application and nomination, rendering her appointment void ab initio. The Court held that the constitutional prescription that impeachable officers may be removed only by impeachment does not bar a quo warranto action to determine the validity of their appointment, as the two remedies address different jurisdictional questions—one the right to hold office, and the other the right to remain in office.