SC OKs release of ex-Chief Justice Corona's retirement benefits
MANILA, Philippines — The Supreme Court has granted the plea of widow of the late Chief Justice Renato Corona, to reap the retirement benefits and other gratuities earned by her husband during his stint with the govenrment and Judiciary.
The SC en banc voted unanimously to declare Corona entitled to retirement benefits and other allowances, and granted his widow, Ma. Cristina Roco Corona, the claim of survivorship. “All benefits granted herein are ordered immediately released to his widow and beneficiary, Ma. Cristina Roco Corona, subject to usual cleareances,” the SC said in a ruling penned by Associate Justice Ramon Paul Hernando.
The thirteen sitting justices, at the time of January 12, concurred with. The copy of the ruling was made public only recently.
Corona was removed from office in May 2012 following an impeachment trial in the Senate for betrayal of public trust for failure to disclose his assets in his Statement of Assets, Liabilities and Net Worth (SALN). He died on April 29, 2016.
The SC held that while tax evasion and forfeiture cases were filed against Corona before the Sandiganbayan, the cases were dismissed when the former chief justice died.
The SC held: “The effects of a judgment on an impeachment complaint extends no further than to removal from office and disqualification form holding any public office.”
Impeachment different from trial court proceedings
Mrs. Corona wrote to the SC on July 13, 2020 stating that her late spouse’s impeachment only divested him of political capacity as chief justice, and prayed that she be allowed to receive retirement benefits and other gratuities.
“She believes that the late chief justice is entitled to these benefits, having toiled for more than 20 years in public service until he was unseated at age 63. She also cites the previous acts of judicial benevolence accorded to a member of Supreme Court magistrates and implores for a similar treatment,” the court ruling read.
In ruling on her plea, the court explained that it does not take part in impeachment cases, as there would likely be two proceedings for the accused: An impeachment trial and a separate criminal case.
“By sharply distinguishing a criminal prosecution from an impeachment, the Framers had made it clear that impeachment is not the means intended to redress and punish offenses against the state, but rather a mere political safeguard designed to preserve the state and its system of laws from internal harm,” the court said.
The tribunal pointed out that impeachment, a purely political proceeding, is designed for an officer’s removal from office, and not as punishment. “No legally actionable liability attaches to the public officer by a mere judgment of impeachment against him or her, and thus lies the necessity for a separate conviction for charges that must be properly filed with courts of law,” it said.
Corona ‘involuntarily retired’
The court held that a public officer who was impeached but whose civil, criminal or judicial liability was not judicially established “may be considered involuntarilty retired from service.”
In Corona’s case, criminal charges against him filed after he was impeached were terminated after he died.
“How, then, will a failure to judicially convict for any liability post-impeachment affect the employment status, retirement benefits, survivorship pension, and other emoluments pertaining to the impeached?” the court said.
It continued: “The Court deems Chief Justice Corona to have involuntarily retired from public service due to the peculiar circumstances surrounding his removal by impeachment, without forfeiture of his retirement benefits and other allowances.”
The SC also noted no provision exists that determines the consequences of impeachment pending resolution of other charges filed against Corona. Following the impeachment court’s judgment, there is no law that orders the automatic cancellation of an impeached official’s post-employment benefits.
Corona’s death and consequent termination of charges against him, “compounded the issue,” the SC said.
“Considering the foregoing, we hold that Chief Justice Corona was involuntarily retired by his conviction arising from impeachment. This is fortified by the failure of other forum to follow through and conclude the proceedings before it that should have brought to fruition the full consequences of his removal from his post,” the SC also said, adding: “This is where equity comes in.”
The tribunal also said that Corona met the requirements under Republic Act 9964, the act on granting retirement and other benefits to members of Judiciary. Those requirements include rendering at least 15 years in government service andbeing at least 60 years old.
“Until his liability under the law is so established before the courts of law, retirement eligibility and benefits have properly accrued to Chief Justice Corona when he was removed by impeachment on May 29, 2012. There being no such determination of liability, his entitlement thereto subsisted,” the ruling further read.
Ouster by SALN
In the same ruling, the SC stressed that ouster by impeachment “is a stunning penalty for its ruins a life.”
It recalled the remarks of the late Sen. Miriam Defensor-Santiago before she cast her vote opposing the impeachment of Corona: “[d]oes omission in the SALN belong to the same class, as for example, treason, bribery…?”
“For the future’s worth, it is herein stressed that the SALN is a tool for public transparency, never a weapon for political vendetta. The Filipino people live, toil, and thrive in a democracy, but the rule of law should not stand parallel to the rule of the mob. Toe this line and the nation may eventually behold the laws that the Courts have forever sworn to uphold battered and bent,” the court also said.
The court voted on the ruling at a time when incumbent SC Associate Justice Marvic Leonen is subjected to an impeachment complaint alleging his supposedly failure to file his SALNs.
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