AM. No. 20-07-10-SC, January 12, 2021
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.
After a heavily-publicized trial, the Senate declared Chief Justice Corona unfit to hold such a lofty position and removed him from his office due mainly to his act of non-declaration of his Statement of Assets, Liabilities, and Net Worth (SALN). The Senate, sitting as an impeachment court, so declared in its final judgment on May 29, 2012. Citing the scholarly views of Father Joaquin G. Bernas (Fr. Bernas), 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 similar treatment.
Issue:
Whether or not 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:
Yes, Mrs. Corona is entitled to the claim of survivorship benefits. Under Section 3 (2), RA 9946, the wordings of which are mirrored by Subsection E, AC No. 81-2010, or the Guidelines on the Implementation of Republic Act No. 9946: Upon the death of a Justice or Judge of any court in the Judiciary, if such Justice or Judge has retired, or was eligible to retire optionally at the time of death, the surviving legitimate spouse shall be entitled to receive all the retirement benefits that the deceased Justice or Judge would have received had the Justice or Judge not died. The surviving spouse shall continue to receive such retirement benefits until the surviving spouse’s death or remarriage. In the instant case, the late Chief Justice practically lived and died a public servant and thus entitled to retirement benefits, which the Court finds no rhyme or reason to withhold from him. In the computation of his retirement benefits, it shall be reckoned from the time he was convicted in the impeachment case. The more important consideration for granting retirement benefits is to compensate for satisfactory service to the government. These are not mere gratuities, but a reward for allotting the best years of a public servant’s life in the service of the country. In the same vein, retirement benefits also form part of the emolument that serves the alternative purpose of encouraging and retaining qualified employees in government service.
Hence, Mrs. Corona is entitled to the payment of Chief Justice Corona’s
survivorship benefits and other allowances
Real LexEcon 