CASE DIGEST: PSBANK vs. Impeachment Court

G.R. No. 200238 : November 20, 2013

PHILIPPINE SAVINGS BANK (PSBANK) and PASCUAL M. GARCIA III, as representative of Philippine Savings Bank and in his personal capacity, Petitioners, v. SENATE IMPEACHMENT COURT, consisting of the senators of the republic of the philippines acting as senator judges, namely: JUAN PONCE ENRILE, JINGGOY EJERCITO ESTRADA, VICENTE C. SOTTO III, ALAN PETER S. CAYETANO, EDGARDO J. ANGARA, JOKER P. ARROYO, PIA S. CAYETANO, FRANKLIN M. DRILON, FRANCIS G. ESCUDERO, TEOFISTO GUINGONA III, GREGORIO B. HONASAN II, PANFILO M. LACSON, MANUEL M. LAPID, LOREN B. LEGARDA, FERDINAND R. MARCOS, JR., SERGIO R. OSMENA III, FRANCIS “KIKO” PANGILINAN, AQUILINO PIMENTEL III, RALPH G. RECTO, RAMON REVILLA, JR., ANTONIO F. TRILLANES IV, MANNY VILLAR; and THE HONORABLE MEMBERS OF THE PROSECUTION PANEL OF THE HOUSE OF REPRESENTATIVES, Respondents.

PERLAS-BERNABE, J.:

FACTS:

Petitioners Philippine Savings Bank (PSBank) and Pascual M. Garcia III (Garcia), as President of PSBank, filed a Petition for Certiorari and Prohibition seeking to nullity and set aside the Resolution of respondent Senate of the Republic of the Philippines, sitting as an Impeachment Court, which granted the prosecution's requests for subpoena duces tecum ad testificandum to PSBank and/or its representatives requiring them to testify and produce before the Impeachment Court documents relative to the foreign currency accounts that were alleged to belong to then Supreme Court Chief Justice Renato C. Corona.

On November 5, 2012, and during the pendency of this petition, PSBank and Garcia filed a Motion with Leave of Court to Withdraw the Petition averring that subsequent events have overtaken the petition and that, with the termination of the impeachment proceedings against former Chief Justice Corona, they are no longer faced with the dilemma of either violating Republic Act No. 6426 or being held in contempt of court for refusing to disclose the details of the subject foreign currency deposits.

HELD: Petition is dismissed.

POLITICAL LAW: justiciable controversy; moot and academic cases


It is well-settled that courts will not determine questions that have become moot and academic because there is no longer any justiciable controversy to speak of.

In Gancho-on v. Secretary of Labor and Employment, the Court ruled: “It is a rule of universal application that courts of justice constituted to pass upon substantial rights will not consider questions in which no actual interests are involved; they decline jurisdiction of moot cases. And where the issue has become moot and academic, there is no justiciable controversy, so that a declaration thereon would be of no practical use or value. There is no actual substantial relief to which petitioners would be entitled and which would be negated by the dismissal of the petition.”

MOOT AND ACADEMIC.

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