AM 20 07 10 SC; (January, 2021) (Digest)
A.M. No. 20-07-10-SC, January 12, 2021
Re: LETTER OF MRS. MA. CRISTINA ROCO CORONA REQUESTING THE GRANT OF RETIREMENT AND OTHER BENEFITS TO THE LATE FORMER CHIEF JUSTICE RENATO C. CORONA AND HER CLAIM FOR SURVIVORSHIP PENSION AS HIS WIFE UNDER REPUBLIC ACT NO. 9946
FACTS
Former Chief Justice Renato C. Corona was impeached by the House of Representatives and, after trial, was convicted by the Senate sitting as an Impeachment Court on May 29, 2012. The Senate found him guilty under Article II of the Articles of Impeachment, mainly for non-declaration of his Statement of Assets, Liabilities, and Net Worth (SALN), and imposed the penalty of removal from office and disqualification from holding any office. He died on April 29, 2016, after which pending criminal charges against him were dismissed. His widow, Ma. Cristina Roco Corona, requested the grant of his retirement benefits and other gratuities under Republic Act No. 9946 , as well as monthly survivorship pension under Administrative Circular No. 81-2010. She argued that the impeachment conviction only removed him from office but did not forfeit his right to retirement benefits, having served in government for over 20 years and reaching the age of 63. The Office of the Chief Attorney recommended denial of the claims for lack of legal basis.
ISSUE
Whether retirement benefits, other gratuities, and survivorship pension should be granted to Mrs. Corona as the spouse of the late Chief Justice Corona despite his ouster by impeachment.
RULING
The Court GRANTED the plea of Mrs. Corona. The effects of a judgment in an impeachment case extend only to removal from office and disqualification from holding any public office; it does not include the forfeiture of retirement benefits. The penalty of removal via impeachment is distinct from dismissal from service in administrative cases, which carries the accessory penalty of forfeiture of benefits. Since the impeachment judgment against Chief Justice Corona did not expressly impose forfeiture of benefits, and as he had reached the compulsory retirement age of 70 and had over 20 years of government service, he was deemed to have retired under Republic Act No. 9946 at the time of his death. Consequently, Mrs. Corona is entitled to receive his retirement benefits and the corresponding survivorship pension.