RE: Impeachment Complaint Against Chief Justice Lourdes Sereno

Section 2, Article XI of the 1987 Constitution states that:

The President, the Vice-President, the Members of the Supreme Court, the
Members of the Constitutional Commissions, and the Ombudsman may be removed from
office, on impeachment for, and conviction of, culpable violation of the Constitution,
treason, bribery, graft and corruption, other high crimes, or betrayal of public trust. All
other public officers and employees may be removed from office as provided by law, but
not by impeachment.

The first complaint, filed by lawyer Larry Gadon, he wants Sereno impeached because she
allegedly committed culpable violation of the Constitution, committed corruption, committed high
crimes, and betrayed public trust for supposedly failing to consult the High Court en banc in
making decisions, for supposedly failing to be truthful in her Statement of Assets, Liabilities, and
Net Worth (SALN), for tax misdeclarations, and for unauthorized expenses, among others.

Corruption:
In his complaint, Gadon accused Sereno of corruption for using public funds to finance
her extravagant and lavish lifestyle by ordering the purchase of a brand-new luxurious
Toyota Land Cruiser 2017 model as her personal vehicle, amounting to more than P5
million.
Gadon also accused Sereno of corruption for using taxpayers money to stay in opulent
hotels when attending conferences in the Philippines and abroad, and flying on business or
first class together with her staff and security. She used public funds to flaunt her
extravagance by unnecessarily bringing a huge entourage of lawyers in her supposed
official foreign trips.

Culpable violation of Constitution, SALN

Gadon said Sereno committed a culpable violation of the Constitution for allegedly failing
to truthfully disclose her SALN.
Gadon alleged that Sereno was untruthful because she deliberately excluded in her
SALN alleged exorbitant lawyers fees amounting to $745,000 or P37 million she
received from the Philippine government.
Sereno is also accused of culpably violating of the Constitution when she manipulated
the shortlist of the Judicial and Bar Council to exclude former Solicitor General Francis
Jardeleza over personal and political reasons, thereby disgracing then Sol. Gen. Jardeleza,
and curtailing the Presidents power to appoint him.

Betrayal of public trust

Gadon accused Sereno of betraying the public trust for her strongly-worded but
misplaced reply on President Rodrigo Dutertes narcolist implicating judges in the drug
trade, urging the magistrates not to surrender to police without an arrest warrant.
Gadon also alleged that Sereno prevented the Justices of the Court of Appeals to do a
courtesy call on President Rodrigo Roa Duterte.
 Gadon also cited Serenos message supposedly attacking Dutertes martial law imposition
in Mindanao, even when petitions questioning the martial law was then pending before the
Supreme Court.
She attacked the imposition of Martial Law in a commencement address, while the
validity of Martial Law was still pending before the Supreme Court, and later continued to
participate in the Courts deliberations, Gadon said.
Gadon also accused Sereno of usurp(ing) the mandate of the Court enbanc by arrogating
to herself alone the running of the Supreme Court and the Judiciary, thereby destroying the
Supreme Court as a collegial body.

Other high crimes

Gadon also accused Sereno of committing other high crimes, when she allegedly
obstructed justice by ordering the Muntinlupa Judges not to issue warrants of arrest
against Senator Leila M. De Lima.
Sereno also allegedly perverted justice when she met with the Presiding Justice and
Associate Justices of the Court of Appeals instructing them not to comply with the
processes of the House of Representatives, which earlier issued a show cause order against
the appellate justices who granted the writ of habeas corpus of the Ilocos Six.
Gadon also accused Sereno of failing to report her extortionate attorneys fees and pay
the appropriate taxes therefor, as well as embellishing her Personal Data Sheet (PDS) in
her application for the Judiciary to overstate her credentials.

The second complaint was filed by the Volunteers Against Crime and Corruption (VACC)
and the Vanguard of the Philippine Constitution, Incorporated (VPCI) said Sereno should be
impeached on the following grounds:
Culpable violation of the Constitution "for issuing an administrative order creating the
new Judiciary Decentralized Office (JDO) and re-opening the Regional Court
Administration Office (RCAO) in Western Visayas in the absence of an authority from the
court en banc"
Culpably violating the constitutional provision that "appointive government officials shall
not hold another public post as provided for by law, in appointing Atty Solomon Lumba as
her Staff Head II"
Culpably violated the Constitution "for appointing Atty Brenda Jay Mendoza as Philippine
Mediation Center Office chief by mere memorandum which was not referred to the court
en banc for its consideration"
Culpably violated the Constitution "for granting to members of her staff travel allowances
for foreign travel charged to the Supreme Court funds without court en banc approval"
Betrayal of public trust "through inexcusable negligence, for sitting on the applications
for the posts of Supreme Court Deputy Clerk of Court and Chief Attorney which have been
vacant for 3 years and 8 months and the two positions for Assistant Court Administrator
which have been vacant for 4 years and 6 months"