1. Overview
Renato Corona was a prominent Filipino judge who served as the 23rd Chief Justice of the Supreme Court of the Philippines from 2010 until his removal from office in 2012. His career, marked by significant roles in law, academia, and government, culminated in a controversial tenure as Chief Justice, which ended with his impeachment and conviction. This landmark event highlighted critical issues of transparency and accountability in public office and sparked national debates on judicial independence and political influence. His life and career underscore the importance of upholding ethical standards and public trust within the Philippine judiciary.
2. Background
Renato Corona's early life and family background provided the foundation for his distinguished career in law and public service.
2.1. Birth and Family
Renato Tereso Antonio Coronado Corona was born on October 15, 1948, at the Lopez Clinic in Santa Ana, Manila, Philippines. His father, Juan M. Corona, was a lawyer from Tanauan, Batangas, while his mother, Eugenia Ongcapin Coronado, was a summa cum laude accounting graduate of the University of Santo Tomas from Santa Cruz, Manila. He was married to Cristina Basa Roco, and together they had three children and six grandchildren.
3. Education
Renato Corona's academic journey included degrees from prestigious institutions, though his doctoral studies later became the subject of controversy, raising questions about the integrity of academic qualifications for public office.
3.1. Early Education and Law Degrees
Corona achieved academic distinction early in his life, graduating with gold medal honors from the Ateneo de Manila grade school in 1962 and high school in 1966. He continued his studies at Ateneo de Manila, earning his Bachelor of Arts degree with honors in 1970, where he also served as the editor-in-chief of The GUIDON, the university student newspaper. He completed his Bachelor of Laws at the Ateneo Law School in 1974, placing 25th out of 1,965 candidates in the Philippine Bar Examination with a grade of 84.6%. Following his law studies, he obtained a Master of Business Administration degree from the Ateneo Professional Schools.
3.2. Graduate Studies and Doctoral Controversy
In 1981, Corona was accepted into the Master of Laws program at Harvard Law School, where he specialized in foreign investment policies and the regulation of corporate and financial institutions. He was conferred the LL.M. degree in 1982. He later earned his Doctor of Civil Law degree from the University of Santo Tomas (UST), graduating summa cum laude and serving as the class valedictorian.
However, his doctorate became a subject of controversy. On December 22, 2011, journalist Marites Dañguilan Vitug of the online site Rappler published an article alleging that the University of Santo Tomas "may have broken its rules" in granting Corona his doctorate in civil law and qualifying him for honors. Vitug claimed that Corona did not submit a dissertation as required by the university and that he exceeded the prescribed study period of five to seven years, having reportedly begun his doctoral work in 2000 or 2001 but only completing it in April 2011. She also noted that he was one of only six graduates to receive the highest honors during the university's 400th anniversary celebration. Additionally, Vitug's book, Shadow of Doubt: Probing the Supreme Court, claimed that there was no record in Ateneo de Manila University's archives of Corona receiving honors with his Bachelor of Arts degree.
In response, the UST Graduate School issued a statement denying any rule-breaking to favor Corona. They asserted that Corona had enrolled in all requisite subjects for the doctorate, attended his classes, passed them, and delivered a "scholarly treatise" as his dissertation in a public lecture. UST, founded in 1611 and recognized as the oldest university in Asia, further stated that as an "autonomous higher educational institution (HEI)" declared by the Commission on Higher Education, it possessed institutional academic freedom to set its own standards of quality and excellence and determine who should be conferred appropriate degrees. The university concluded that issues regarding Corona's residency and academic honors were moot, as they fell under the university's institutional academic freedom. UST also questioned Vitug's objectivity, citing her previous disagreements with Corona and the Supreme Court, and her support for Associate Justice Antonio Carpio's bid for the chief justiceship. Vitug, when asked to comment on UST's statement, responded that the university's position essentially implied that "we have rules, but we can violate them by invoking academic freedom and autonomy."
4. Early Career and Appointments
Before his elevation to Chief Justice, Renato Corona built a professional life spanning private legal practice, academia, and various government roles.
4.1. Legal and Academic Career
Renato Corona began his professional journey as a private law practitioner, applying his legal expertise in various cases. Concurrently, he dedicated a portion of his career to academia, serving as a law professor at the Ateneo de Manila University School of Law. These roles allowed him to contribute to both the practical application and theoretical understanding of law.
4.2. Service in Government and Appointment as Associate Justice
Corona transitioned into public service, holding significant positions within the Cabinet under two former presidents. He served under President Fidel V. Ramos and later under President Gloria Macapagal Arroyo. His tenure in the executive branch provided him with extensive experience in government administration. On April 9, 2002, President Arroyo appointed him as an Associate Justice of the Supreme Court of the Philippines, marking his entry into the highest judicial body of the country.
5. Chief Justice Tenure
Renato Corona's period as the 23rd Chief Justice of the Philippines was notable for the circumstances of his appointment and a landmark judicial action concerning agrarian reform.
5.1. Appointment and Constitutional Basis
On May 12, 2010, Renato Corona was appointed the 23rd Chief Justice of the Supreme Court of the Philippines by President Gloria Macapagal Arroyo. This appointment occurred just two days after the 2010 Philippine general election and approximately one month before President Arroyo's term was set to expire, as he succeeded Reynato Puno, who had reached the mandatory retirement age.
His appointment drew criticism from then-presidential candidate Benigno Aquino III, who argued that the timing violated the election-period prohibition against presidential appointments. However, Aquino's criticism was based on an erroneous interpretation, as the prohibition he cited applies only to the Executive branch.
The constitutional basis for Corona's appointment was clarified by the Supreme Court itself in the case of de Castro v. JBC. The Court held that Article VII of the Philippine Constitution, titled "Executive Department," specifically applies only to the Executive Branch of the government. In contrast, Article VIII of the Philippine Constitution is titled "Judicial Department." The Court emphasized that any prohibition regarding appointments to the Judiciary should be found under Article VIII, and no such prohibition against election-period presidential appointments exists within this article. The Supreme Court stated that if the framers had intended to extend the prohibition from Section 15, Article VII to the appointment of Supreme Court Members, they would have explicitly done so, most likely in Section 4(1), Article VIII. The Court further noted that the non-applicability of Section 15, Article VII to appointments in the Judiciary was confirmed by then Senior Associate Justice Regalado to the Judicial and Bar Council (JBC) in 1998, in discussions concerning the constitutionality of appointments to the Court of Appeals during an election period.
On the contrary, the Court highlighted that under the constitutional provisions for the Judicial Department, Section 4(1) and Section 9, Article VIII, mandate the President to fill a vacancy in the Supreme Court within 90 days from its occurrence. It is also mandatory for the JBC to submit a list of nominees to the President to enable an appointment within this 90-day period. The Court concluded that the President had an "imperative duty" under the Constitution to fill vacancies created by retirements within 90 days.
5.2. The Hacienda Luisita Case
A significant judicial action during Chief Justice Corona's tenure was the Supreme Court's landmark decision on the Hacienda Luisita case. Hacienda Luisita is a vast 16 K acre (6.45 K ha) sugar estate spanning 11 villages in Tarlac City, La Paz, and Concepcion towns, historically part of farmlands owned by the Cojuangco family's Central Azucarera de Tarlac.
In 1988, then-President Corazon Aquino, a member of the Cojuangco family, signed Republic Act No. 6657, also known as the Comprehensive Agrarian Reform Law. This law allowed for the distribution of shares of stocks instead of actual land, signaling the beginning of the Comprehensive Agrarian Reform Program (CARP). One of the clauses of CARP provided for a Stock Distribution Option (SDO), which allowed compliance by distributing shares of the hacienda to farm workers rather than the land itself. The Cojuangco family availed of this option, with their Tarlac Development Corp. (TADECO) forming Hacienda Luisita Inc. (HLI).
The following year, two referendums on the SDO were held. However, several farm workers alleged that they were coerced into agreeing to the stock distribution. Approximately 12 K acre (4.92 K ha) of land were converted into shares, with TADECO owning 67 percent and farm workers on the 1989 master list controlling 33 percent. By 2003, about 5,000 farm workers filed a supplemental petition seeking the revocation of the SDO and the actual distribution of lands to them.
In November 2004, the farmers initiated a strike protesting mass retrenchment and demanding higher pay. This strike was violently dispersed by the police under the direction of then-Labor Secretary Patricia Santo Tomas, resulting in the deaths of 7 people and the imprisonment of 133 others. This tragic event became known as the Hacienda Luisita Massacre.
In 2005, the Department of Agrarian Reform (DAR) recommended the revocation of the SDO. By December of that year, the Presidential Agrarian Reform Council (PARC) issued Resolution No. 2005-32-01, which recalled and revoked the SDO plan of TADECO/HLI and placed the lands covered by the SDO under the compulsory coverage of CARP.
On July 5, 2011, the Supreme Court, led by Chief Justice Corona, upheld the decision by the Department of Agrarian Reform and the PARC, thereby revoking the 1989 stock distribution option. However, the Court also allowed each farm worker to choose between a piece of farmlot or shares of stocks. In November 2011, in a 56-page ruling, all 14 Supreme Court justices, including Corona, unanimously voted en banc that the contested land should be distributed by Hacienda Luisita Inc. (HLI) to the original 6,296 farmer-beneficiaries, in accordance with the Presidential Agrarian Reform Council's order from December 2005. The Court also lifted a temporary restraining order (TRO) that HLI had previously secured. The Cojuangco group was granted a ten-year period to distribute the lands to the farmers as stipulated by the ruling.
6. Impeachment and Conviction
Renato Corona's tenure as Chief Justice concluded with his impeachment and conviction, a significant event in Philippine political history that brought issues of accountability and judicial independence to the forefront.
6.1. Initiation of Impeachment Proceedings
On December 12, 2011, an impeachment complaint was filed against Chief Justice Corona in the House of Representatives of the Philippines. A substantial majority of 188 out of the 285 members of the House signed the complaint. Given that the 1987 Constitution requires only a vote of one-third of the entire membership of the House (or 95 signatures) for an impeachment, the complaint was subsequently transmitted to the Senate of the Philippines for trial.
6.2. Grounds for Impeachment and Defense
The impeachment complaint against Corona primarily cited his alleged failure to disclose his Statement of Assets, Liabilities, and Net Worth (SALN) to the public, as required by the Constitution. The complaint also accused Corona of consistently rendering biased decisions in cases related to the administration of former President Gloria Macapagal Arroyo.
Corona vehemently denied the charges, asserting that the case against him was politically motivated and part of then-President Benigno Aquino III's broader campaign to persecute his perceived political enemies. He explicitly linked the impeachment to the Hacienda Luisita case, stating that the "whole sordid affair has all been about politics from beginning to end." He claimed it was related to the 10.00 B PHP compensation that the President's family reportedly sought for land that Corona argued was "simply lent to them by the government." Corona further suggested that the impeachment aimed "to terrorize and instill a chilling effect on the justices of the Supreme Court to be able to bend their decisions in favor of the Malacañang tenant." He highlighted that the Supreme Court had heard oral arguments on the Cojuangco Aquinos' Hacienda Luisita case in August 2010, after he became Chief Justice, and issued a landmark decision adverse to the Cojuangco Aquino family in November 2011, just a month before the impeachment complaint was filed.
Regarding the non-disclosure of assets, Corona argued that he was not legally required to disclose his 2.40 M USD in foreign currency deposits because the Foreign Currency Deposits Act (Republic Act No. 6426) guarantees their secrecy. He also contended that his peso accounts contained "co-mingled funds," including those belonging to his relatives.
Corona pointed to several events that demonstrated President Aquino's animosity towards him. In December 2011, President Aquino publicly criticized Corona and lambasted the Supreme Court at the First National Criminal Justice Summit hosted by the Department of Justice. The Supreme Court later issued a statement expressing its disturbance, noting that while it was the President's prerogative to speak his mind, it was "quite unusual" for the Chief Executive to publicly denounce the court's independent actions to its members' faces. Aquino also attacked Corona at the 30th anniversary celebration of the Makati Business Club. In February 2012, Aquino escalated his attacks on Corona during the 33rd founding anniversary of a province, with Senator Edgardo Angara, one of the judges in Corona's impeachment trial, present just meters away. Throughout the trial, Corona's supporters showed solidarity with him through signs and their presence at the Supreme Court.
6.3. Senate Trial and Conviction
The impeachment trial of Chief Justice Renato Corona took place in the Senate. On May 29, 2012, after weeks of proceedings and the presentation of evidence, he was found guilty by the Senate of Article II of the Articles of Impeachment filed against him. This article specifically cited his failure to disclose to the public his statement of assets, liabilities, and net worth. Of the twenty-three senators, twenty voted to convict him, exceeding the two-thirds majority (16 votes) required to remove him from office. Following his conviction, Corona declared that "ugly politics prevailed" and maintained that his "conscience is clear." His removal marked the first time that a high-level Philippine official had been impeached and convicted.
6.4. Allegations of Incentives and Political Influence
The impeachment trial was followed by allegations of improper influence and incentives offered to senators, raising significant concerns about judicial independence. On September 25, 2013, Senator Jinggoy Estrada, who had voted to convict Corona, claimed in a privilege speech that all senators who voted for conviction, with the exception of Bongbong Marcos, Joker Arroyo, and Miriam Defensor-Santiago, had received 50.00 M PHP each. Estrada later clarified that this was an "appeal" and not a bribe. However, multiple allies of President Aquino in the Senate subsequently confirmed that 50.00 M PHP had indeed been released, but they denied any connection between these funds and their vote to convict Corona.
Further allegations of political pressure emerged on January 20, 2014, when then-Senator Bong Revilla claimed that then-President Aquino and several of his allies had personally asked him to vote for Corona's conviction. Revilla recounted that he was picked up by Mar Roxas, who was then the Secretary of the Department of Transportation and Communications and a known ally of President Aquino, and brought to the President's residence. Revilla stated that Roxas explained why Corona should be impeached. Revilla then quoted President Aquino as directly appealing to him, saying, "My friend, do it for me as a favor. (Corona) must be impeached." While the President's spokesperson confirmed that President Aquino had indeed met with Revilla and other senators, the spokesperson denied the allegation that Aquino had instructed them to vote for Corona's conviction. Malacañang Palace, however, declined to comment on the propriety of President Aquino's personal meetings with the senator-judges during the trial.
7. Legal Aftermath and Post-Supreme Court
Following Renato Corona's removal from office and his subsequent death, legal proceedings related to his alleged undeclared wealth continued, ultimately resulting in the dismissal of all remaining cases against him and his heirs.
7.1. Post-Death Legal Proceedings
In June 2016, the Sandiganbayan Third Division, a special court that handles graft and corruption cases in the Philippines, dismissed the pending criminal cases against Renato Corona, citing his death.
On November 3, 2022, the Sandiganbayan further dismissed the last remaining case against Corona, his heirs, trustees, assignees, transferees, and successors-in-interest. The court's decision stated that the respondents were able to "adequately prove that their income could enable them to acquire the questioned assets." The Sandiganbayan noted that it remained undisputed that both Corona and his wife came from "families of very comfortable means." The court found that even before his appointment to the Supreme Court, Chief Justice Corona possessed the financial capacity to shoulder significant expenses and had lived a "very contented life with his family." It highlighted his success as a lawyer and stated that his "engagement with the private sectors appeared to have been lucrative," as evidenced by his positions in private banking and tax consulting institutions, as well as his role as a Professor of Law at the Ateneo de Manila University School of Law. The court also determined that the computations presented by the prosecution had merely added Corona's earned income without considering his money market placements and the substantial interest income accrued over ten-year periods. The decision concluded by emphasizing a principle previously stressed by the Supreme Court in In Re: Ma. Cristina Roco Corona, stating that the SALN (Statement of Assets, Liabilities, and Net Worth) is a tool for public transparency and "never a weapon for political vendetta." On January 30, 2023, the Sandiganbayan decision was declared final and executory.
8. Death
Renato Corona died at the age of 67 on April 29, 2016, at 1:48 a.m. at The Medical City in Pasig. His death was attributed to complications arising from a heart attack. He had also been suffering from other chronic health conditions, including kidney disease and diabetes.
9. Notable Opinions
Renato Corona authored or co-authored several significant judicial opinions and dissenting opinions during his time as an Associate Justice and Chief Justice of the Supreme Court of the Philippines, reflecting his judicial philosophy and contributions to Philippine jurisprudence.
- [http://sc.judiciary.gov.ph/jurisprudence/2003/jul2003/153888.htm Islamic Da'Wah Council v. Office of the Executive Secretary (2003)] - on the right of the national government to act as the exclusive authority to issue halal certifications.
- [http://sc.judiciary.gov.ph/jurisprudence/2003/jul2003/152154.htm Republic v. Sandiganbayan (2003)] - on the forfeiture of Swiss assets belonging to the Marcos family.
- [http://sc.judiciary.gov.ph/jurisprudence/2003/nov2003/160261_corona.htm Francisco v. House of Rep. (2003) - Separate Opinion] - on the impeachment resolution against Chief Justice Hilario Davide, Jr..
- [http://sc.judiciary.gov.ph/jurisprudence/2005/feb2005/152900.htm Uy v. PHELA Trading (2005)] - on constitutional right to counsel.
- [http://sc.judiciary.gov.ph/jurisprudence/2005/mar2005/144801.htm Taruc v. De la Cruz (2005)] - on court jurisdiction over challenges to religious excommunication.
- [http://sc.judiciary.gov.ph/jurisprudence/2005/sep2005/141524.htm Neypes v. Court of Appeals (2005)] - on the period for appeal from decisions of trial courts.
- [http://sc.judiciary.gov.ph/jurisprudence/2006/october2006/174153_corona.htm Lambino v. COMELEC (2006) - Dissenting Opinion] - on People's Initiative as a mode to amend the Constitution.