Case Digest (A.M. No. 20-07-10-SC) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In A.M. No. 20-07-10-SC, Mrs. Ma. Cristina Roco Corona filed a letter dated July 13, 2020 before the Supreme Court En Banc, seeking the grant of retirement and other benefits to the late former Chief Justice Renato C. Corona and survivorship pension as his legitimate spouse under Republic Act No. 9946. Renato C. Corona was appointed Chief Justice on May 12, 2010 after serving eight years as Associate Justice. On December 12, 2011, the House of Representatives adopted eight Articles of Impeachment against him for betrayal of public trust, culpable violation of the Constitution for non-disclosure of SALN, graft and corruption, and other grounds. After a highly publicized trial, the Senate—sitting as Impeachment Court—convicted him on Article II on May 29, 2012 and imposed removal and perpetual disqualification under Article XI, Section 3(7) of the 1987 Constitution. No motion for reconsideration was filed. Chief Justice Corona reached the mandatory retirement age but died on April Case Digest (A.M. No. 20-07-10-SC) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- Renato C. Corona was appointed Chief Justice of the Supreme Court on May 12, 2010, after eight years as Associate Justice.
- On December 12, 2011, the House of Representatives filed eight Articles of Impeachment against him for betrayal of public trust, culpable violation of the Constitution, and graft and corruption, notably his failure to disclose his Statement of Assets, Liabilities, and Net Worth (SALN).
- Impeachment Trial and Aftermath
- On May 29, 2012, the Senate, sitting as an Impeachment Court, convicted Chief Justice Corona on Article II (non-declaration of SALN), resulting in his removal from office and disqualification to hold any public office. No motion for reconsideration was filed.
- Corona’s health deteriorated, and he died on April 29, 2016. Pending criminal charges before the Sandiganbayan (graft, corruption, tax evasion) were dismissed due to his death.
- Petition for Benefits
- On July 13, 2020, Ma. Cristina Roco Corona, the widow, filed A.M. No. 20-07-10-SC requesting her late husband’s retirement benefits and her survivorship pension under Republic Act No. 9946 (RA 9946) and Administrative Circular No. 81-2010 (AC 81-2010).
- She alleged that removal by impeachment merely divested Corona of his political capacity and did not forfeit his post-employment benefits.
- The Office of the Chief Attorney (OCAt) reported on September 28, 2020, advising denial, reasoning that impeachment is not equivalent to voluntary retirement or resignation due to incapacity under RA 9946.
Issues:
- Whether Chief Justice Renato C. Corona, upon removal by impeachment and disqualification, may be considered involuntarily retired and thereby entitled to retirement benefits and other allowances under RA 9946.
- Whether Ma. Cristina Roco Corona, as the surviving legitimate spouse of the late Chief Justice, is entitled to survivorship pension and related benefits under RA 9946 and AC 81-2010.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)