Re: Cornejo
REITERATIONFacts
The Antecedents: Associate Justice Maria Cristina J. Cornejo (Justice Cornejo) of the Sandiganbayan had been on sick leave since June 13, 2016. Clinical abstracts from Cardinal Santos Medical Center revealed she was diagnosed with multiple severe conditions, including acute cerebrovascular disease in bilateral cerebral and cerebellar hemispheres, systemic lupus erythematous, pancytopenia, stage III colon cancer, and acute kidney injury. Procedural History: On October 20, 2016, Sandiganbayan Presiding Justice Amparo M. Cabotaje-Tang informed the Supreme Court (SC) of Justice Cornejo's condition. The SC directed the Head of the Supreme Court Medical Services to certify her capability to function. On December 13, 2016, Dr. Prudencio P. Banzon, Jr., Supreme Court Senior Chief Staff Officer, Medical and Dental Services, reported that Justice Cornejo was 'physically and medically incapacitated to perform her duties, and responsibilities as Sandiganbayan Justice.' The Petition: On January 13, 2017, Justice Cornejo wrote to Chief Justice Maria Lourdes P. A. Sereno requesting the approval of her optional retirement effective March 1, 2017, citing serious health concerns. Due to her physical state, the letter bore her thumbprint instead of a signature. Presiding Justice Cabotaje-Tang recommended the approval of this request on February 6, 2017.
Issue(s)
Whether Justice Cornejo's request for optional retirement should be granted, and whether it should be modified to a retirement due to permanent total disability under Republic Act No. 910.
Ruling
The Supreme Court (SC) resolved to DECLARE Associate Justice Ma. Cristina J. Cornejo to have suffered permanent total disability effective March 1, 2017, and GRANTED her the lump sum permanent disability benefits provided for in Section 3 of Republic Act No. 910, as amended. The Fiscal Management and Budget Office was DIRECTED to compute the benefits and make them available to her or her duly constituted guardian.
Ratio Decidendi
On Issue 1: The Supreme Court (SC) ruled to grant the retirement request but modified the classification to disability retirement. The Court reasoned that disability retirement is specifically designed for employees who are incapacitated by involuntary causes such as illness. Applying the social justice principle established in Re: Gruba, the Court held that those forced to cease service for disabilities beyond their control deserve the full protection of retirement laws. The medical reports from the Supreme Court Medical and Dental Services unequivocally established that Justice Cornejo was physically and medically incapacitated. Under Section 3 of Republic Act No. 910, as amended by Republic Act No. 9946, a Justice who retires due to permanent disability contracted during incumbency is entitled to a 10-year lump sum gratuity. Given Justice Cornejo's 39 years of government service and her actual medical condition, the Court determined that she warranted the maximum benefits allowed by law. Consequently, the Court treated her thumbprinted request for optional retirement as a request for disability retirement to ensure the processing of the 10-year lump sum gratuity.
Main Doctrine
The Supreme Court (SC) maintains a policy of social justice regarding retirement benefits, particularly for those in the Judiciary who are forced to retire due to involuntary causes like illness. When a Justice or Judge is certified as physically and medically incapacitated to perform their duties, the Court may treat a request for optional retirement as a retirement due to permanent disability. Under Section 3 of Republic Act No. 910, as amended, such disability retirement entitles the retiree to a lump sum gratuity equivalent to ten (10) years' salary and allowances, provided the disability was contracted during their incumbency and prior to the date of retirement.