The Supreme Court has denied the Motion for Reconsideration filed by the House of Representatives and the Senate of the Philippines, affirming its earlier ruling in the impeachment case docketed as G.R. Nos. 278353 and 278359. The Court held that the transmittal of the Articles of Impeachment was invalid because it was already barred by Article XI, Section 3(5) of the Constitution.
The Case
The petitioners, led by Jonard C. Dayap and other named individuals, challenged the impeachment proceedings before the Supreme Court. The respondents are the House of Representatives, represented by House Speaker Ferdinand Martin G. Romualdez, and the Senate of the Philippines, represented by Senate President Francis Joseph G. Escudero.
According to the decision, at the time the House acted on the fourth impeachment complaint endorsed by at least one-third of all House members, three impeachment complaints had already been properly filed and endorsed under the first mode and remained pending. The respondents sought reconsideration of the Court's July 25, 2025 Decision.
The Issue
The Court addressed whether the respondents complied with the constitutional requirements of impeachment, particularly the periods mandated under Article XI, Section 3(2) of the Constitution, and whether the fourth impeachment complaint was barred by the one-year bar under Article XI, Section 3(5).
The Ruling
The Court denied the Motion for Reconsideration. It affirmed that the House of Representatives has the sole prerogative to initiate impeachment complaints and to promulgate its rules of impeachment in accordance with the requirements of the Constitution, but held that its Rules must be consistent with the provisions of the Constitution.
The Court found that respondents were not able to comply with Article XI, Section 3(2) by putting the three endorsed impeachment complaints in the Order of Business of the House of Representatives within 10 session days. Thus, the fourth impeachment complaint, even if endorsed by more than one-third of all the members of the House of Representatives, is barred by Article XI, Section 3(5) of the Constitution.
The Court ruled that the transmittal of the Articles of Impeachment was not rendered invalid merely because it was based on the fourth complaint, which was endorsed by at least one-third of the members of the House of Representatives. Rather, the transmittal was invalid because it was already barred by Article XI, Section 3(5) of the Constitution.
By the Numbers
- G.R. Nos. 278353 and 278359
- 10 session days — the period within which a verified impeachment complaint must be included in the Order of Business
- 3 session days — the period within which a complaint must be referred to the proper committee
- 60 session days — the period within which the Committee must submit its report
- One-third of all members of the House — required endorsement under the second mode
- One-year bar under Article XI, Section 3(5)
- Three impeachment complaints pending under the first mode; the fourth complaint under the second mode
- July 25, 2025 — date of the original Decision; July 8, 2025 Resolution referenced
The Court's Reasoning
The Court clarified that the impeachment process is primarily a legal, political, and constitutional procedure, and not a purely political proceeding. This means the Bill of Rights, especially the due process clause and the right to speedy disposition of cases, applies to the entire impeachment process, although its application in the initiation stage is sui generis.
The Court explained that for the initiation stage of impeachment, which is a constitutional process, a session day is a calendar day in which the House of Representatives holds a session. Neither the secretary general nor the speaker of the House is granted any discretion to determine when this period commences.
The Court clarified that the Constitution accords no priority to either the first or the second mode of initiating an impeachment complaint. However, the second mode will be barred under Article XI, Section 3(5) if there are pending complaints under the first mode that violate the periods mandated in the Constitution.
The Court reiterated the doctrine in Gutierrez v. House of Representatives, which sought to prevent the filing of frivolous or sham complaints. It noted that, mindful of the doctrine of separation of powers, while it may define what constitutes initiation for constitutional purposes, it will not intrude upon the discretion of the House of Representatives to determine whether an impeachment complaint is sufficient in form and in substance.
Source: Resolution in G.R. Nos. 278353 and 278359, penned by SAJ Leonen.
This report summarizes a public Supreme Court decision and is not legal advice.