A.M. No.

16-10-05-SB March 14, 2017

RE: MEDICAL CONDITION OF ASSOCIATE JUSTICE MARIA CRISTINA J.

CORNEJO, SANDIGANBAYAN

Facts: Sandiganbayan Associate Justice Maria Cristina J. Cornejo (Justice Cornejo) has
been on sick leave since June 13, 2016. According to the attached clinical abstract from
Dr. Santos/Tubig, Justice Cornejo was diagnosed with acute cerebrovascular disease
and all other disorders. Dr. Prudencio P. Banzon, Jr., Supreme Court Senior Chief Staff
Officer, Medical and Dental Services, opined that as of November 25, 2016, Justice
Cornejo was "physically and medically incapacitated to perform her duties, and
responsibilities as Sandiganbayan Justice." Justice Cornejo wrote Chief Justice Maria
Lourdes P. A. Sereno to request the approval of her optional retirement, effective March
1, 2017, due to serious health concerns.

Issue: Does the social justice principle apply to those who are forced to cease from
service for disabilities beyond their control?

Ruling: Yes. Disability retirement is conditioned on the incapacity of the employee to

continue his or her employment for involuntary causes such as illness or accident. The
social justice principle behind retirement benefits also applies to those who are forced to
cease from service for disabilities beyond their control.

COURAGE vs. Commissioner of Internal Revenue, G.R. No. 213446, July 3,

2018

Facts: On August 6, 2014, petitioners Confederation for Unity, Recognition and

Advancement of Government Employees (COURAGE), et al., filed a Petition for
Prohibition and Mandamus, imputing grave abuse of discretion on the part of
respondent CIR in issuing RMO No. 23-2014. According to petitioners, RMO No. 23-
2014 classified as taxable compensation, the following allowances, bonuses,
compensation for services granted to government employees, which they alleged to be
considered by law as non-taxable fringe and de minimis benefits. Petitioners also claim
that RMO No. 23-2014 violates the equal protection clause of the Constitution as it
discriminates against government officials and employees by imposing fringe benefit tax
upon their allowances and benefits.

Issue: Are sections III, IV, and VII of RMO No. 23-2014 valid and constitutional?

Ruling: Yes. Sections III, IV and VII of RMO No. 23-2014 are declared valid and
constitutional inasmuch as they merely mirror the provisions of the National Internal
Revenue Code of 1997, as amended. However, the Court cannot rule on petitioners'
claims of exemption from withholding tax on compensation income because these
involve issues that are essentially factual or evidentiary in nature, which must be raised
in the appropriate administrative and/or judicial proceeding.
COURAGE vs. Commissioner of Internal Revenue, G.R. No. 213446, July 3,
2018

Issue: Can this ruling be applied retroactively?

Ruling: No. As a measure of equity and compassionate social justice, the Court deems
it proper to clarify and declare, pro hac vice, that its ruling on the validity of Sections III
and IV of the assailed RMO is to be given only prospective effect