Sara Z. Duterte v. House of Representatives, et al. ​

Case Digest: G.R. Nos. 278353 and 278359 ​

Case Title: Sara Z. Duterte v. House of Representatives, et al. ​

Date of Promulgation:July 25, 2025 ​

Facts of the Case

1. Filing of the First Three Impeachment Complaints:

   • On December 2, 2024, private individuals and organizations filed the first impeachment complaint against Vice President Sara Z. Duterte, endorsed by Representative Percival Cendena of Akbayan Party-list. The complaint alleged culpable violation of the Constitution, graft and corruption, bribery, betrayal of public trust, and other high crimes. ​

   • On December 4, 2024, a second impeachment complaint was filed by another group, endorsed by Representatives France Castro, Arlene Brosas, and Raoul Daniel Manuel. ​ This complaint focused on alleged misuse of PHP 612.5 million in confidential funds and betrayal of public trust. ​

   • On December 19, 2024, a third impeachment complaint was filed by religious workers and civil society members, endorsed by Representatives Gabriel Bordado Jr. and Lex Anthony Cris Colada. This complaint alleged plunder, graft, and corruption related to the vice president's handling of confidential funds. ​

2. Inaction on the First Three Complaints:

   • Despite being filed and endorsed, the House of Representatives did not act on the first three complaints within the constitutionally mandated period. ​ The complaints were included in the Order of Business on February 5, 2025, but were not referred to the Committee on Justice for deliberation. ​

3. Filing of the Fourth Impeachment Complaint:

   • On February 5, 2025, during a caucus, 215 members of the House of Representatives signed a fourth impeachment complaint against Vice President Duterte. This complaint was filed under Article XI, Section 3(4) of the Constitution, which allows impeachment complaints to be initiated by at least one-third of the House members. ​ The complaint alleged corruption, assassination threats against the president, and incitement to insurrection. ​

4. Archiving of the First Three Complaints:

   • On the same day, the House archived the first three impeachment complaints, effectively dismissing them. ​ The fourth impeachment complaint was immediately transmitted to the Senate. ​

5. Legal Challenges:

   • Vice President Duterte and a group of lawyers led by Atty. ​ Israelito Torreon filed separate petitions before the Supreme Court, challenging the constitutionality of the fourth impeachment complaint. ​ They argued that the fourth complaint violated the one-year bar rule under Article XI, Section 3(5) of the Constitution and due process requirements.

Issues ​

1. Whether the Supreme Court has jurisdiction to review impeachment proceedings. ​

2. Whether the House of Representatives complied with the constitutional requirements for handling the first three impeachment complaints. ​

3. Whether the fourth impeachment complaint violated the one-year bar rule under Article XI, Section 3(5) of the Constitution. ​

4. Whether the fourth impeachment complaint violated Vice President Duterte's right to due process. ​

5. Whether the Senate acquired jurisdiction over the impeachment proceedings based on the fourth impeachment complaint. ​

Supreme Court Rulings and Discussions

Issue 1: Jurisdiction of the Supreme Court ​

• Ruling: The Supreme Court ruled that impeachment proceedings are subject to judicial review, especially when constitutional violations are alleged. ​

• Discussion: 

  • The Court emphasized its expanded jurisdiction under Article VIII, Section 1 of the Constitution, which allows it to review acts of any branch of government for grave abuse of discretion. ​

  • Impeachment is a sui generis process that is primarily legal but has political characteristics. ​ While the House of Representatives has the exclusive power to initiate impeachment, this power is not immune from judicial scrutiny when constitutional boundaries are breached.

  • The Court cited Francisco, Jr. v. House of Representatives, where it held that impeachment proceedings are justiciable when constitutional violations are alleged. ​

    
    

Issue 2: Compliance with Constitutional Requirements for the First Three Complaints ​

• Ruling: The Supreme Court found that the House of Representatives failed to act on the first three impeachment complaints within the constitutionally mandated period, effectively dismissing them.

• Discussion: 

  • Article XI, Section 3(2) of the Constitution requires that a verified impeachment complaint be included in the Order of Business within 10 session days and referred to the proper committee within three session days thereafter. ​

  • The Court ruled that the secretary general and the speaker of the House have a ministerial duty to ensure compliance with these timelines. ​ They cannot delay or refuse to act on properly filed and endorsed complaints. ​

  • The first three complaints were archived without being referred to the Committee on Justice, violating the constitutional process. ​ The Court declared that these complaints were effectively dismissed. ​

    
    

Issue 3: Violation of the One-Year Bar Rule ​

• Ruling: The Supreme Court held that the fourth impeachment complaint violated the one-year bar rule under Article XI, Section 3(5) of the Constitution. ​

• Discussion: 

  • The one-year bar rule prohibits initiating impeachment proceedings against the same official more than once within a year. ​

  • The Court clarified that the one-year bar is reckoned from the dismissal or termination of the first impeachment complaint. ​ Since the first three complaints were dismissed on February 5, 2025, no new impeachment complaint could be initiated against Vice President Duterte until February 6, 2026. ​

  • The fourth impeachment complaint was filed on the same day the first three complaints were archived, making it constitutionally barred. ​

    
    

Issue 4: Violation of Due Process ​

• Ruling: The Supreme Court ruled that the fourth impeachment complaint violated Vice President Duterte's right to due process. ​

• Discussion: 

  • Due process requires that the respondent be given an opportunity to be heard and that the allegations be supported by clear and convincing evidence. ​

  • The Court found that the fourth impeachment complaint was filed, processed, and transmitted to the Senate on the same day, leaving no time for deliberation or for the respondent to respond to the allegations. ​

  • The Court emphasized that impeachment proceedings must adhere to the principles of fairness and transparency. ​ The rushed filing and transmittal of the fourth complaint undermined these principles. ​

    
    

Issue 5: Senate Jurisdiction ​

• Ruling: The Supreme Court held that the Senate did not acquire jurisdiction over the impeachment proceedings based on the fourth impeachment complaint. ​

• Discussion: 

  • The Court declared the fourth impeachment complaint null and void ab initio due to violations of the one-year bar rule and due process requirements.

  • Since the complaint was constitutionally infirm, the Senate could not validly constitute itself as an impeachment court to try the case. ​

Final Ruling

• The Supreme Court partially granted the petitions filed by Vice President Duterte and Atty. ​ Torreon et al. ​

• The Court declared the first three impeachment complaints effectively dismissed due to the House's inaction.

• The fourth impeachment complaint was declared barred by the one-year rule, unconstitutional, and null and void ab initio. ​

• The Senate did not acquire jurisdiction over the impeachment proceedings. ​

• The Court ruled that no new impeachment complaint against Vice President Duterte may be initiated ​

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