Case Summary (A.M. No. 20-07-10-SC)
Petitioner and Respondent
Petitioner: Ma. Cristina Roco Corona, widow of the late Chief Justice.
Respondent: Supreme Court En Banc, in its administrative capacity to resolve entitlement to RA 9946 benefits and Administrative Circular No. 81-2010 pension.
Key Dates
• Appointment as Chief Justice: May 12, 2010
• Articles of Impeachment filed: December 12, 2011
• Senate conviction and removal: May 29, 2012
• Chief Justice Corona’s death: April 29, 2016
• Widow’s petition docketed: July 13, 2020
• Decision date: May 15, 2023 (1987 Constitution applicable)
Applicable Law
• 1987 Constitution, Article XI, Sections 2 & 3 (impeachment process, effects limited to removal and disqualification)
• Republic Act No. 9946 (judicial retirement and survivorship benefits)
• Administrative Circular No. 81-2010 (implementation guidelines for RA 9946)
• Republic Act No. 10154 (timely release of retirement benefits)
Facts and Procedural History
Chief Justice Corona was impeached and removed solely for non-declaration of his SALN. Post-impeachment, he reached retirement age and faced outstanding criminal and administrative charges, all dismissed upon his death. His widow received accrued leave credits and now seeks statutory retirement gratuities and a monthly survivorship pension.
Issue for Resolution
Whether the post-impeachment removal of Chief Justice Corona precludes entitlement to retirement benefits and whether his surviving spouse is entitled to survivorship pension under RA 9946 and AC 81-2010.
Nature and Effect of Impeachment
Impeachment under the 1987 Constitution yields only removal from office and disqualification from public office; it is distinct from criminal punishment and does not automatically result in forfeiture of retirement rights. Separate judicial proceedings are required to impose further sanctions.
Equitable Construction and Involuntary Retirement
Absent a final judicial conviction on pending charges, the Court deems Chief Justice Corona to have been involuntarily retired. Equity fills the statutory gap, preventing denial of earned post-employment privileges when no tribunal established liability beyond impeachment.
Entitlement Under RA 9946
Corona satisfied the optional retirement criteria—at least sixty years old with fifteen years of service and three consecutive years in the judiciary—thus accruing rights to a five-year lump-sum retirement benefit computed from his May 29, 2012 ouster.
Survivorship Pension Eligibilit
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Facts and Antecedents
- Renato C. Corona served as Associate Justice (2002–2010) and as Chief Justice of the Supreme Court (May 12, 2010 – May 29, 2012).
- Articles of Impeachment filed December 12, 2011, alleging betrayal of public trust, culpable violation of the Constitution, graft and corruption.
- Eight articles detailed specific misdeeds: partiality in Arroyo‐related cases, non‐disclosure of SALN, flip‐flopping decisions, separation‐of‐powers violation, res judicata disregard, usurpation of investigatory power, favoritism in TRO issuance, failure to account for Judiciary funds.
Impeachment Trial and Judgment
- Senate, sitting as Impeachment Court, conducted a high‐profile trial.
- On May 29, 2012, by 20–3 vote (two‐thirds), found guilty exclusively under Article II (non‐disclosure of SALN).
- Imposed penalty: removal from office and disqualification to hold any public office.
- No motion for reconsideration filed; judgment became final.
Post‐Impeachment Proceedings and Demise
- No separate criminal convictions collated against him by final judgment prior to his death.
- Pending graft, tax evasion, perjury, forfeiture cases before regular courts were dismissed upon his death on April 29, 2016.
- Renato C. Corona died at age 63, after having “reached the legal age of retirement” but before resolution of other charges.
Claim for Retirement Benefits and Survivorship Pension
- Widow Ma. Cristina Roco Corona, by letter dated July 13, 2020 (A.M. No. 20-07-10-SC), sought:
• Retirement benefits and other gratuities due under Republic Act No. 9946.
• Monthly survivorship pension under Administrative Circular No. 81-2010. - She argued:
• Impeachment divested only political capacity; did not void retirement entitlement.
• Late Chief Justice rendered over 20 years of public service and reached the optional retirement age of 60.
• Administrative clearances and monetized leave credits had been issued per the Court’s 2019 resolution.
Report and Recommendation of the Office of the Chief Attorney
- OCAt concurred that impeachment results only in removal and disqualification.
- Interpreted RA 9946’s “resignation by reason of incapacity” and “permanent disability” provisions narrowly as physical incapacity, not political removal.
- Found no legal basis to treat removal by impeachment as optional retirement under RA 9946.
- Recommended denial of both retirement benefits and survivorship pension