EN BANC [ 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
HERNANDO, J.:
Before the Court is the supplication for the grant of post-employment and survivorship benefits of Ma.
Cristina Roco Corona (Mrs. Corona), as the spouse of impeached former Chief Justice Renato C.
Corona
on the alleged grounds of betrayal of public trust, culpable violation of the Constitution, and graft
and corruption. But chiefly on the ground of culpable violation of the Constitution on the ground that
he failed to disclose his statement of SALN as required under Sec 17, Art 11, Constitution.
Whether 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:
The effects of a judgment on an impeachment complaint extends no further than to
removal from office and disqualification from holding any public office.
Forum shopping could not be invoked against Mrs Corona.
Elements of FC:
1. identity of parties, or at least such parties as represent the same interests in both
actions;
2. identity of rights asserted and reliefs prayed for, the relief being founded on the same
facts; and
3. the identity of the two preceding particulars, such that any judgment rendered in the
other action will, regardless of which party is successful, amounts to res judicata in the
action under consideration. Res judicata refers to the rule that a final judgment or decree
on the merits by a court of competent jurisdiction is conclusive of the rights of the parties
or their privies in all later suits on all points and matters determined in the former suit.
Impeachment being sui generis, its final culmination, whether a dismissal or a conviction,
would not constitute res judicata for the basic reason that the principle of res judicata
does not find application in purely political processes.
The criminal law principle of double jeopardy also finds no application against an
impeached public officer.
Elements of DJ:
(1) a first jeopardy attached prior to the second; (2) the first jeopardy has been validly
terminated; and (3) a second jeopardy is for the same offense as in the first. A first jeopardy
attaches only (a) after a valid indictment; (b) before a competent court; (c) after
arraignment; (d) when a valid plea has been entered; and (e) when the accused has been
acquitted or convicted, or the case dismissed or otherwise terminated without his express
consent. Suffice it to state that a first jeopardy finds no opportunity to arise at that point, as
the essence of impeachment is not criminal in nature.
An action for quo warranto will likewise proceed independently of the impeachment
proceedings.
Impeachment Quo Warranto
Nature. Impeachment is political Quo warranto is judicial
Jurisdiction. In impeachment, the Instituted either by the (1) Solicitor General
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Congress is the prosecutor, the trier, and in behalf of the Republic of the Philippines or
the judge (2) by an individual claiming the public office
in issue, both of which petitions are
cognizable only by the Supreme Court.
Grounds. Confirm the Breach of the trust Determines the legal right, title, eligibility, or
reposed by the Filipino people upon the qualifications of the incumbent to the
impeachable official contested public office
Applicable procedure. The 1987 Rules of Court.
Constitution, as supplemented by the
internal rules of procedure of the Congress,
directs the course of impeachment
proceedings
Limitations. The end result of an Ouster from office is likewise meted, but the
impeachment proceeding is the removal of Court can likewise impose upon the public
the public officer, and his or her perpetual officer additional penalties such as
political disqualification from holding public reimbursement of costs pertaining to the
office. rightful holder of the public office and such
further judgment determining the respective
rights in and to the public office, position, or
franchise of all the parties to the action as
justice requires
An impeached public officer whose civil, criminal, or administrative liability was not
judicially established may be considered involuntarily retired from service.
A respondent in impeachment proceedings does not risk forfeiture of the constitutional rights
to life, liberty, or property. No provision exists that lays out the consequences of his
impeachment pending the resolution of the other charges filed against him. Criminal cases
were also filed after his impeachment.
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. Equity is the material that fills in the open spaces in the silence,
obscurity, or insufficiency of the law. Courts of law are courts of equity.
An impeached public officer whose civil, criminal, or administrative liability was not
judicially established is entitled to the retirement benefits provided under RAs 9946 and
8291.
However, whether criminal, civil, or administrative, no court imposed any such liability upon
the late Chief Justice. Impeachment is only preparatory to liability. Since a removal by
impeachment does not explicitly provide for forfeiture as a consequence thereof, as
opposed to a criminal conviction carrying the penalty of perpetual or absolute disqualification,
an impeached official, like former Chief Justice Corona, cannot be deprived of his retirement
benefits on the sole ground of his removal.
Retirement laws are liberally construed and administered in favor of the persons
intended to be benefited, and all doubts are resolved in favor of the retiree to
achieve their humanitarian purpose.
Mrs. Corona is entitled to the payment of Chief Justice Corona's survivorship benefits and
other allowances under RA 9964. It needs emphasizing that the peculiarities of the present case
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find no directly-analogous precedent, both in law or in fact, that the Court may rely on. Thus being
the case, the liberalities granted to a judge can be allowed to the Chief Justice.
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