by Legally Brown

Re: LETTER OF MRS. MA. CRISTINA ROCO CORONA REQUESTING GRANT OF RETIREMENT, AM No. 20-07-10-SC, 2021-01-12

Facts:

Renato Coronado Corona became the Chief Justice of the Philippines on May 12, 2010 after an eight-year stint as Associate Justice in the High Court. He occupied the judicial apex very momentarily: a year after his appointment as Chief Justice, Articles of Impeachment were filed against him and he was eventually indicted by the House of Representatives under Section 2, Article VI of the 1987 Constitution[3] on the alleged grounds of betrayal of public trust, culpable violation of the Constitution, and graft and corruption.

No objection or a motion for reconsideration was interposed against the judgment of the Senate. Having been dishonorably stripped of his public office and having undergone a most difficult and stressful trial, the Chief Justice's health quickly deteriorated culminating to his death on April 29, 2016. The separate criminal charges for graft and corruption then pending before the Sandiganbayan, as well as the tax evasion and forfeiture cases, were all necessarily dismissed in view of the Chief Justice's demise.

The widow of the Chief Justice, Mrs. Corona, now pleads for judicial benevolence.In a letter dated July 13, 2020 now docketed as A.M. No. 20-07-10-SC, Mrs. Corona asserts, albeit unseeking of its reversal, that the Senate judgment removing the Chief Justice from office should be voided for insufficiency of evidence and noncompliance with Section 14, Article VIII of the Constitution.

Citing the scholarly views of Father Joaquin G. Bernas (Fr. Bemas), Mrs. Corona insists that her late spouse's ouster by impeachment merely divested him of his political capacity as Chief Justice of the Supreme Court. Thus, she prays 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 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 number of Supreme Court magistrates and implores for a similar treatment.

Mrs. Corona further claims that her prayer for monetary reliefs have already been impliedly granted in view of the issuance of clearances by the section heads of the Supreme Court's administrative arm and her receipt of her husband's monetized accrued leave credits, all in accordance with the Court's September 3, 2019 Resolution in A.M. No. 19-09-02-SC.

The matter was then referred to the Office of the Chief Attorney (OCAt) for its report and evaluation.

the OCAt shared Mrs. Corona's opinion that a verdict in an impeachment case has the sole effect of ousting the errant official from his/her post.Its concurrence with Mrs. Corona, however, ended there. In its interpretation of Sections 1 and 3 of RA 9946, the OCAt submits that it will be a stretch to consider former Chief Justice Corona's removal by impeachment tantamount to an act of resignation by reason of incapacity to discharge the duties of the office that he held. While forfeiture of retirement benefits is not expressly included as a penalty in a judgment on an impeachment proceeding, the OCAt posits that the gap be left as it is and referred to legislative discretion. For lack of supporting legal basis, the OCAt recommended the denial of Mrs. Corona's claims for the release of her late husband's retirement benefits and survivorship pension.The matter is now before this Court for resolution.

Issues:

IssueRipe for judicial determination is the question of whether retirement benefits, other gratuities, and survivorship pension should be accorded to Mrs. Corona as the spouse of the late Chief Justice Corona despite the latter's ouster by impeachment.

Ruling:

The Court grants the plea of Chief Justice Corona's widow.The effects of a judgment on animpeachment complaint extendsno further than to removal fromoffice and disqualification fromholding any public office.

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. [17] Precisely, it was not crafted to mete out punishment.[18]In the same vein, impeachment does not imply immunity from court processes, nor does it preclude other forms of discipline.

(7) Judgment in cases of impeachment shall not extend further than removal from office and disqualification to hold any office under the Republic of the Philippines, but the party convicted shall nevertheless be liable and subject to prosecution, trial, and punishment according to law. (Emphasis supplied)Father Bernas elucidated on the matter:The object of the process is not to punish but only to remove a person from office. As Justice Storey put it in his commentary on the Constitution, impeachment is "a proceeding, purely of a political nature, is not so much designed to punish an offender as to secure the state against gross political misdemeanors. It touches neither his person nor his property, but simply divests him of his political capacity." Put differently, removal and disqualification are the only punishments that can be imposed upon conviction on impeachment. Criminal and civil liability can follow after the officer has been removed by impeachment. Prosecution after impeachment does not constitute prohibited double jeopardy.[21] (Emphasis supplied)

Principles:

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