Supreme Court Upholds Final Ruling on Duterte Impeachment Case
The Supreme Court of the Philippines has upheld with finality its earlier decision declaring the Articles of Impeachment against Vice President Sara Z. Duterte unconstitutional. In a unanimous ruling, the Court en banc denied the House of Representatives' motion for reconsideration, solidifying the legal stance on this high-profile case.
Unanimous Decision and Constitutional Grounds
During a press conference on Thursday, January 29, 2026, SC spokesperson Camille Ting announced that the en banc had junked the House's bid to overturn its July 25, 2025 decision. The Court affirmed that the fourth impeachment complaint, transmitted to the Senate on February 5, 2025, was barred by the Constitution's one-year prohibition on initiating impeachment proceedings against the same official.
All participating justices voted to deny the motion, with Associate Justice Alfredo Benjamin Caguioa taking no part and Associate Justice Maria Filomena Singh on leave. The High Court reiterated that the impeachment complaint violated Article XI, Section 3(5) of the Constitution, which explicitly prohibits more than one impeachment proceeding against the same official within a one-year period.
Clarification on Impeachment Initiation
The Court provided detailed explanations regarding the initiation of impeachment complaints. It stated that the first three impeachment complaints against Duterte, filed under the first mode of impeachment, were deemed initiated even though the House did not act upon them. This interpretation is crucial for understanding the one-year bar rule.
Furthermore, the Constitution requires that impeachment complaints filed under Article XI, Section 3(2) must be included in the House's Order of Business within 10 session days. The Court clarified that session days refer to calendar days when the House actually holds sessions, not legislative session days as broadly understood.
Precedent and Procedural Details
Citing its earlier ruling in Gutierrez v. House of Representatives, the Court outlined specific conditions under which an impeachment complaint under the first mode is considered initiated for purposes of the one-year bar. These include:
- A properly verified and endorsed impeachment complaint is referred to the Committee on Justice.
- A properly verified and endorsed impeachment complaint is not placed in the Order of Business of the House of Representatives within 10 session days, or referred to the Committee on Justice after it has been put in the Order of Business within three session days.
- No Articles of Impeachment are transmitted to the Senate before the House of Representatives adjourns sine die, meaning initiation must occur during the term of Congress.
House Rules and Constitutional Modes
The Court affirmed the House of Representatives' power to promulgate its own Rules on Impeachment but clarified how these rules interact with the Constitution's two modes of initiating impeachment. Spokesperson Ting explained, However, it clarified that Section 2 of the House Rules, as it is currently worded, requires referral to the Committee on Justice even when filed through the second mode.
The second mode, provided in Article XI, Section 3(4) of the Constitution, allows the endorsement of at least one-third of the members of the House to be sufficient for transmittal. The Court noted that based on current wording, even complaints under the second mode may be referred to the Committee on Justice—but only for limited purposes such as verifying endorsements and consolidating complaints.
Due Process and Transmittal Requirements
In a significant ruling, the Court emphasized that due process applies to impeachment proceedings, describing it as a constitutional safeguard against arbitrariness and unfairness. The decision states, The due process clause embodies the fundamental constitutional commitment to reasonableness, fairness, and non-arbitrariness.
The Court also detailed procedural requirements: transmittal of Articles of Impeachment must occur during a plenary session, with all members furnished copies. Transmittal to the Senate requires either a one-third vote under the first mode or proof of one-third endorsement under the second mode.
Immediate Effect and Conclusion
The Resolution is immediately executory upon digital service on all parties, in accordance with A.M. No. 25-05-16-SC, the Guidelines on the Transition to Electronic Filing in the Supreme Court. This ruling marks a pivotal moment in Philippine constitutional law, reinforcing procedural safeguards in impeachment processes and upholding legal standards in political proceedings.
