 Traditionally, the most senior Associate Justice was appointed to fill any permanent vacancy to the seat of the Chief Justice, though this tradition was not always observed.Upon the retirement of Chief Justice Hilario Davide Jr. in 2005, Puno, as the senior Associate Justice, was a leading candidate for appointment as the next Chief Justice.However, President Gloria Macapagal-Arroyo instead appointed Associate Justice Artemio Panganiban as Chief Justice, marking the first time in 20 years that the senior Associate Justice was bypassed.