MANILA — The Supreme Court has unanimously granted the plea of the wife of the late Chief Justice Renato Corona for retirement benefits, other allowances and survivorship benefits, in a ruling where the high court warned against the consequences of impeachment and weaponizing of statements of assets, liabilities and net worth (SALN).
Appointed as top magistrate in May 2010, Corona was removed in May 2012 following a Senate impeachment conviction for failure to disclose to the public his SALN.
He died in April 2016 at the age of 67.
In July 2020, Corona’s wife, Cristina, wrote to the SC claiming that her late husband was entitled to retirement benefits, other gratuities and monthly survivorship pension, having been in public service for 20 years when he was removed at age 63.
In a January 12, 2021 decision penned by Associate Justice Ramon Paul Hernando, the high court granted Mrs. Corona’s plea, ruling that the effect of an impeachment judgment only extends to removal and disqualification from office and did not create a legally actionable liability which requires a separate judicial proceeding.
The SC said that an impeached public officer whose civil, criminal or administrative liability was not judicially established may be considered “involuntarily retired.”
“The Court deems Chief Justice Corona to have been involuntarily retired from public service due to the peculiar circumstances surrounding his removal by impeachment, without forfeiture of his retirement benefits and other allowances,” it said.
Charges against Corona for graft and corruption, tax evasion and forfeiture were terminated upon his death.
The high court noted the absence of any provision on the consequences of impeachment before other charges are resolved and invoked equity.
“Notably, from the time the impeachment court rendered its judgment, there has been no law that commands the automatic cancellation of post-employment benefits and other privileges pertaining to the impeached official. Chief Justice Corona’s untimely demise and the consequent termination of the other charges against him all the more compounded the issue,” it said.
“This is where equity comes in. Under the prevailing circumstances, the fairer and more equitable treatment of the present claim for post-employment privileges is to first consider Chief Justice Corona as involuntarily retired, rather than to dismiss it outright without citing any legal basis,” it added, referring to the Court Attorney’s recommendation to deny the claim.
The Court Attorney had said Corona neither retired nor resigned, making him ineligible for retirement benefits.
But the SC said Corona met the requirements for optional retirement having reached age of 60 while in public service, explaining that retirement laws are liberally construed and administered in favor of the persons intended to be benefited as a “reward for allotting the best years of a public servant’s life in the service of the country.”
Ruling on Mrs. Corona’s entitlement to survivorship benefits, the SC said mere eligibility for optional retirement at the time of death, not actual retirement, is enough to grant survivorship benefits to the surviving spouse of a deceased magistrate.
WARNING ON IMPEACHMENT, SALNs
In the same ruling, the Supreme Court warned against the consequences of impeachment and weaponizing SALNs:
“Ouster by impeachment is a stunning penalty for it ruins a life, as the late Senator Miriam Defensor-Santiago had exclaimed before casting her vote against its imposition upon then Chief Justice Corona. A staunch supporter against the removal of Chief Justice Corona, Senator Defensor-Santiago phrased the unanswered question as a seeming rhetoric: ‘[d]oes omission in the SALN belong to the same class, as for example, treason, bribery…?’”
“For 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,” it said.
A divided Supreme Court, in May 2018, voted 8-6 to remove THEN Chief Justice Maria Lourdes Sereno through a previously-untested quo warranto petition due to her non-filing of SALNs, treating it as an integrity issue.
Associate Justice Alfredo Benjamin Caguioa called the ruling “seppuku without honor” while Associate Justice Marvic Leonen called it a “legal abomination.”
Of the 8 who voted for Sereno’s ouster, only Chief Justice Diosdado Peralta and Associate Justice Alexander Gesmundo currently remain in Court, while Senior Associate Justice Estela Perlas-Bernabe joined Caguioa, Leonen and 3 other now-retired justices to vote against her ouster.
The Corona ruling came at a time a sitting member of the SC — Leonen — is facing an impeachment complaint over SALN issues before the House of Representatives.
The SC had unanimously blocked efforts to secure his SALNs for impeachment/quo warranto purposes.
FROM THE ARCHIVES
EFFECT OF THE RULING
The Corona ruling did not say if the grant of retirement benefits to an impeached official without judicial determination of liability also applies to an official ousted through quo warranto.
But it clearly laid out the distinction between impeachment and quo warranto.
“Impeachment is political; quo warranto is judicial. In impeachment, Congress is the prosecutor, the trier, and the judge, whereas quo warranto petitions are instituted either by the Solicitor General in behalf of the Republic of the Philippines or by an individual claiming the public office in issue, both of which petitions are cognizable only by the Supreme Court,” it said.
“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 added.
The ruling noted that impeachment can end in removal in office and perpetual political disqualification, while in quo warranto, the Supreme Court may impose additional penalties aside from ouster.
Corona is the first magistrate to have been removed from office through impeachment, while Sereno, the first female justice appointed to the top post, is the first to be removed through quo warranto.