Removal from office via impeachment only results in removal and disqualification from holding public office and does not, by itself, cause the forfeiture of accrued retirement benefits; forfeiture requires a separate judicial conviction for criminal, civil, or administrative liabilities, which did not occur in the case of the late Chief Justice Corona due to his death terminating such proceedings.

Renato C. Corona served as an Associate Justice for eight years before being appointed Chief Justice in 2010. In 2011, impeachment proceedings were initiated against him by the House of Representatives on grounds including betrayal of public trust and culpable violation of the Constitution. Following a trial, the Senate convicted him in 2012 primarily based on Article II concerning his failure to accurately declare his Statement of Assets, Liabilities, and Net Worth (SALN), leading to his removal from office. Subsequently, criminal, tax, and forfeiture cases were filed against him but were all dismissed following his death in 2016, prior to any final judgment.

• Renato C. Corona was appointed Chief Justice of the Supreme Court on May 12, 2010, after serving as Associate Justice since April 2002.
• In 2011, the House of Representatives initiated impeachment proceedings against him on grounds of betrayal of public trust, culpable violation of the Constitution, and graft and corruption, outlined in eight Articles of Impeachment.
• On May 29, 2012, the Senate, sitting as an Impeachment Court, convicted Chief Justice Corona under Article II (failure to disclose his SALN), resulting in his removal from office and disqualification from holding any future public office.
• No appeal or motion for reconsideration was filed against the Senate's judgment.
• Following his impeachment, separate tax evasion charges, criminal cases for perjury, administrative complaints, and a civil forfeiture case were filed against the former Chief Justice in 2014.
• Renato C. Corona passed away on April 29, 2016.
• Due to his death prior to final judgment, all pending criminal, civil, and administrative cases against him were subsequently dismissed.
• On July 13, 2020, his widow, Mrs. Ma. Cristina Roco Corona, submitted a letter to the Supreme Court requesting the grant of retirement benefits due to her late husband and the corresponding survivorship pension for herself under RA 9946.
• Mrs. Corona argued that the impeachment only removed his political capacity and did not forfeit accrued benefits, citing his extensive public service (over 20 years) and eligibility under retirement laws (removed at age 63).
• The Supreme Court's Office of the Chief Attorney (OCAt), upon referral, recommended denying the request, arguing that impeachment removal did not fit the criteria under RA 9946 (retirement at 70 or resignation due to incapacity) and that forfeiture gaps should be left to legislative action.

• Mrs. Corona asserted that the Senate's impeachment judgment was flawed (though not seeking its reversal) and only divested her husband of his political office, not his accrued rights.
• She contended that the late Chief Justice Corona was entitled to retirement benefits under RA 9946 and survivorship pension under AC 81-2010, having served over 20 years in government, including his time in the judiciary until his removal at age 63.
• Mrs. Corona invoked precedents of judicial benevolence shown to other magistrates and requested similar treatment.
• She claimed that the prior issuance of clearances and the receipt of monetized leave credits for the late Chief Justice impliedly granted her request for benefits.
• Mrs. Corona argued that her husband met the requirements for optional retirement under RA 9946 at the time of his removal: being a magistrate, over 60 years old, with at least 15 years of government service, the last three continuously in the Judiciary.

• The Office of the Chief Attorney (OCAt) argued that Chief Justice Corona's removal via impeachment did not qualify as retirement (reaching age 70) or resignation due to incapacity under Section 1 of RA 9946.
• OCAt submitted that interpreting "resignation by reason of incapacity" to include impeachment removal would be a strained interpretation of the law.
• OCAt posited that while forfeiture of benefits is not an explicit penalty in the constitutional provision for impeachment judgment, the resulting legal gap concerning benefits should be addressed by the legislature, not filled by judicial interpretation in favor of granting the benefits.

• Whether the surviving spouse of a Chief Justice removed from office by impeachment is entitled to retirement benefits and survivorship pension when the Chief Justice died before the final resolution of subsequent criminal, civil, and administrative charges filed against him.
• Whether removal by impeachment automatically carries with it the accessory penalty of forfeiture of retirement benefits and other allowances.

• The Supreme Court granted the petition of Mrs. Ma. Cristina Roco Corona, declaring the late Chief Justice Renato C. Corona entitled to retirement benefits under RA 9946, and Mrs. Corona entitled to the corresponding survivorship pension.
• The Court reasoned that impeachment, as defined by the Constitution, is a political process whose judgment is limited to removal from office and disqualification from holding future office; it does not automatically include forfeiture of accrued retirement benefits.
• Forfeiture of retirement benefits is an accessory penalty tied to a final judicial conviction in criminal, civil, or administrative proceedings establishing liability, which did not occur as the cases against CJ Corona were terminated by his death.
• Applying equity and liberal construction of retirement laws, the Court deemed CJ Corona involuntarily retired due to the unique circumstances (impeachment removal followed by death precluding final judgment on other charges).
• The Court found that CJ Corona met the qualifications for optional retirement under Section 1 of RA 9946 at the time of his removal (age over 60, over 15 years government service, last 3 years in Judiciary), making him eligible for retirement benefits.
• Consequently, as the legal surviving spouse of an eligible magistrate, and not being disqualified herself, Mrs. Corona is entitled to the survivorship benefits provided under RA 9946 and AC 81-2010.

• Nature and Effect of Impeachment: Defined as a political process, distinct from judicial proceedings, primarily intended to remove an official from office rather than to punish. The Court applied this doctrine to rule that the impeachment conviction only led to CJ Corona's removal and disqualification, not the automatic forfeiture of benefits, which requires separate judicial action.
• Separation of Powers: The principle that divides governmental powers among branches. Implicitly used to distinguish the political act of impeachment by Congress from the judicial power to determine criminal, civil, or administrative liability and impose penalties like forfeiture.
• Due Process of Law: The constitutional guarantee that no person shall be deprived of life, liberty, or property without due process. The Court invoked this to hold that forfeiture of retirement benefits (considered property) requires a judicial finding of liability through established procedures, which was absent in CJ Corona's case due to his death.
• Liberal Construction of Retirement Laws: The principle that retirement statutes should be interpreted generously in favor of the retiree to fulfill their humanitarian purpose of providing financial support. The Court applied this doctrine to grant benefits despite the ambiguity created by impeachment and death, considering CJ Corona's long service.
• Equity Jurisdiction: The authority of courts to apply principles of fairness and justice when strict legal rules are inadequate or absent. The Court used equity to address the legal gap concerning the status of benefits for an impeached official whose subsequent cases were terminated by death, deeming him involuntarily retired and thus eligible.
• Res Judicata and Double Jeopardy: The Court explicitly stated these legal principles do not apply to link impeachment with subsequent judicial proceedings, because impeachment is political, not judicial (for res judicata) or criminal (for double jeopardy) in nature. This reinforced the separation between the impeachment outcome and the need for a separate judicial finding for forfeiture.

• "Equity is the ink that writes the law and not its inverse."
• "Judgment in cases of impeachment shall not extend further than removal from office and disqualification to hold any office under the Republic of the Philippines, but the party convicted shall nevertheless be liable and subject to prosecution, trial, and punishment according to law." (Citing 1987 Constitution, Art. XI, Sec. 3(7))
• "The object of the process is not to punish but only to remove a person from office... removal and disqualification are the only punishments that can be imposed upon conviction on impeachment." (Citing Fr. Joaquin Bernas)
• "Impeachment is, thus, designed to remove the impeachable officer from office, not punish him. It is purely political, and it is neither civil, criminal, nor administrative in nature."
• "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."
• "Public officers and employees who have spent the best years of their lives serving the government and the public should not be made to wait to receive benefits which are due to them under the law." (Citing RA 10154, Sec. 1)
• "These [retirement benefits] are not mere gratuity, but a reward for allotting the best years of a public servant's life in the service of the country."

• Nixon v. United States (506 U.S. 224): Referenced to support the principle that impeachment is a political process distinct from judicial trials, with constitutionally limited penalties (removal/disqualification).
• United States v. Isaacs (493 F.2d 1124): Cited to show that impeachment does not preclude criminal prosecution for offenses committed by an official.
• Nixon v. Sirica (487 F.2d 700): Cited to illustrate that holding public office does not shield an official from legal obligations common to all citizens.
• Republic v. Sereno (G.R. No. 237428): Distinguished impeachment (political) from quo warranto (judicial) proceedings.
• Talens-Dabon v. Arceo (699 Phil. 1), Sabitsana, Jr. v. Villamor (A.M. No. RTJ-90-474), Meris v. Ofilada (419 Phil. 603), Castillo v. Calanog (276 Phil. 70), Junio v. Judge Rivera, Jr. (509 Phil. 65): Cited as examples where the Court showed humanitarian consideration or granted partial benefits/clemency to dismissed lower court judges, providing a comparative basis for considering equity in Corona's case, while noting the distinct lack of final judicial conviction in his situation.
• Government Service Insurance System v. De Leon (649 Phil. 610): Cited as authority for the liberal construction of retirement laws.
• Reyes v. Lim (456 Phil. 1): Referenced for the definition and role of equity jurisdiction when law is insufficient.
• Re: Requests for Survivorship Pension Benefits... (A.M. No. 17-08-01-SC): Explained the application and evolution of RA 910 and RA 9946 concerning judicial retirement and survivorship benefits, forming the basis for Mrs. Corona's claim.
• Heirs of Marcelo Sotlo v. Palicte (726 Phil. 651): Provided definition of forum shopping and res judicata, showing why res judicata does not apply to impeachment.
• Cerezo v. People (665 Phil. 365): Stated requisites for double jeopardy, demonstrating why it does not bar prosecution after impeachment.

• 1987 Constitution, Article XI, Section 2 (Impeachable Officers and Grounds)
• 1987 Constitution, Article XI, Section 3(7) (Limited Judgment in Impeachment)
• Republic Act No. 9946 (Amending RA 910 - Judiciary Retirement Law), Sections 1 & 3
• Republic Act No. 10154 (Early Release of Retirement Benefits Act), Sections 1, 3, 4, 5
• Administrative Circular No. 81-2010 (Implementing Rules for RA 9946), Subsection E (Survivorship Benefits)
• Revised Penal Code, Article 30(4) (Accessory penalty of loss of retirement pay upon perpetual/absolute disqualification)
• Revised Rules on Administrative Cases in the Civil Service, Section 52 (Administrative penalties including forfeiture)
• Rules of Court, Rule 66, Section 9 (Judgment in Quo Warranto actions)
• US Constitution, Art. I, Sec. 3, Cl. 6 & 7; Art. II, Sec. 4 (Cited for historical context and comparative law on impeachment)
• 1935 Constitution, Art. IX, Sec. 4; 1973 Constitution, Art. XIII, Sec. 4 (Cited for historical continuity of impeachment provisions)