Corona re retirement
(A.M. No. 20-07-10-SC. January 12, 2021)
Facts:
Before the court is the supplication for the grant of post-employment and survivorship benefits of Ma. Cristina Roco Corona, as the spouse of former CJ Renato Corona.
CJ Corona put into office on May 12, 2010. A year later, Articles of Impeachment were filed against him. CJ Corona was indicted by the House of Representatives under Section 2 Article 6 of the 1987 Constitution, on the alleged grounds of betrayal of public trust, culpable violation of the Constitution, and graft and corruption.
Among those charged against him were partiality in cases involving the Arroyo administration, being a midnight appointment as chief justice, failure to disclose his SALN (as required by Section 17 Article 11 of the 1987 Constitution), and failure to account for the Judiciary Development Fund (JDF) and Special Allowance for the Judiciary (SAJ).
CJ Corona was impeached on May 29, 2012. While the criminal and civil charges were still being tried, CJ Corona died on April 29, 2016. Thus, the criminal charges for graft and corruption were dismissed.
Following this, Mrs. Corona sent the letter to the Supreme Court on July 13, 2020, asking to void the Senate judgment for insufficiency of evidence and violation of Section 14 Article 8 of the Constitution.
Issue:
W/N Mrs. Corona should be accorded retirement benefits, other gratuities and survivorship pension as the spouse of the late CJ Corona despite the latter’s ouster by impeachment
Held: Petition is granted
The sole effect of impeachment is the removal from office and disqualification from holding any public office. Citing cases from the American Jurisprudence (where the law on impeachment in the country is heavily based on) there is mutual exclusivity of impeachment proceedings and court trial.
Impeachment is not crafted to mete out punishment. It is made to secure the state against gross political misdemeanors. As such, it does not touch the person or property, but only divests him of his political capacity.
No legally actionable liability attaches to the public officer by a mere judgment of impeachment against him or her, and thus lies the necessity for a separate conviction for charges that must be properly filed with courts of law.
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