Despite his impeachment as head of judiciary in 2012, the Supreme Court (SC) has ruled that the late Chief Justice Renato C. Corona was entitled to his retirement benefits equivalent to a five-year lump sum of his salary and other allowances.
In a unanimous full court decision written by Associate Justice Ramon Paul L. Hernando, the SC also ruled that Corona’s widow, Ma. Cristina Roco Corona, is entitled to survivorship benefits reckoned from the lapse of the five-year period of lump sum.
Corona was impeached for non-declaration of his statements of assets, liabilities and networth (SALNs). This is the first case in the history of the country’s judiciary.
The SC declared that Corona involuntarily retired from public service “due to the peculiar circumstances surrounding his removal by impeachment….”
Corona’s case was different from that of Maria Lourdes P. Sereno who was ousted by the SC in 2018 in a quo warranto case filed by the Office of the Solicitor General (OSG), the SC said.
“Impeachment is political; quo warranto is judicial. Impeachment proceedings seek to confirm and vindicate the breach of the trust reposed by the Filipino people upon the impeachable official, but quo warranto determines the legal right, title, eligibility, or qualifications of the incumbent to the contested public office,” it said.
Citing records, the SC said that after the Senate announced Corona’s impeachment on May 29, 2012, tax evasion charges, 32 criminal cases for perjury, 33 administrative complaints for violation of the Republic Act 6713 of the Code of Conduct of Ethical Standards for Public Officials and Employees, and a civil case for forfeiture were slapped against I 2014.
But the charges, however, were terminated upon Corona’s death in 2016, the SC said.
“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 SC asked.
Answering its own query, the SC said:
“A respondent in impeachment proceedings does not risk forfeiture of the constitutional rights to life, liberty, or property.
“A separate determination of liability under the courts of law is necessary to withhold such rights. Sans judicial conviction, the impeached official shall only be removed from office, with the Senate being empowered with the discretion to impose the additional penalty of permanent disqualification from holding any and all further public office.
“Having been removed by the Congress from office with a lifetime ban from occupying any and all future public posts, but without a proper determination of or even a basis for any recoverable liability under the law due to causes beyond his control, Chief Justice Corona may be considered involuntarily retired from public service.”
The SC cited the similar provisions on impeachment and accountability of public officials in the 1935, 1973 and 1987 constitution.
Provisions in the 1935, 1973 and 1987 Constitution declared: “Judgments in cases of impeachment shall be limited to removal from office and disqualification to hold any office of honor, trust, or profit under the Republic of the Philippines, but the party convicted shall nevertheless be liable and subject to prosecution, trial, and punishment, in accordance with law.”
The SC also said:
“Impeachment proceedings are entirely separate, distinct, and independent from any other actionable wrong or cause of action a party may have against the impeached officer, even if such wrong or cause of action may have a colorable connection to the grounds for which the officer have been impeached.”
But it said that “an impeached public officer whose civil, criminal, or administrative liability was not judicially established may be considered involuntarily retired from service.”
The SC decision granted the plea of Mrs. Corona in a letter dated July 13, 2020.
Mrs. Corona told the SC that her late spouse's ouster by impeachment merely divested him of his political capacity as Chief Justice of the Supreme Court.
She pleaded that she be allowed to reap the retirement benefits and other gratuities provided under Sections 1 and 3 of Republic Act No. 9946 (RA 9946), and monthly survivorship pension under Administrative Circular No. 81-2010 (AC 81-2010).
She pointed out that her late husband was entitled to these benefits, having toiled for more than 20 years in public service until he was unseated at age 63.