Supreme Court Bars Impeachment Complaint Against VP Sara Duterte: 1-Year Rule and Due Process Upheld

Yasser Aureada
Jul 26
2 min read

Breaking Legal Update – July 25, 2025

In a landmark decision, the Supreme Court of the Philippines En Banc unanimously declared the impeachment proceedings against Vice President Sara Z. Duterte unconstitutional, citing the one-year bar rule and violation of due process rights under the 1987 Constitution.

The Court held that the Articles of Impeachment, transmitted by the House of Representatives on February 5, 2025, were void as they breached both procedural and constitutional safeguards.

“There is a right way to do the right thing at the right time. This is what the Rule of Just Law means. This is what fairness or due process of law means—even for impeachment.”— Senior Associate Justice Marvic M.V.F. Leonen, Duterte v. House of Representatives

Case Background

The impeachment complaints stemmed from:

Three initial complaints filed by private individuals on December 2, 4, and 19, 2024
A fourth complaint filed via House Resolution, endorsed by at least one-third of House Members on February 5, 2025, and transmitted the same day to the Senate

However, since the earlier complaints were terminated on February 5, 2025, and the one-year bar under Article XI, Section 3(5) had not lapsed, the Supreme Court ruled the transmission invalid. No new complaint may be filed until February 6, 2026.

Due Process Applies to Impeachment

In a detailed opinion, the Court emphasized that impeachment is a legal and constitutional process—not purely political. It ruled that due process rights under the Bill of Rights must be respected even during political proceedings.

The House of Representatives was reminded that:

Articles of Impeachment must include sufficient evidence
The respondent must be heard before the Senate assumes jurisdiction
All House members must have access to supporting documents before endorsing
Any act or omission charged must be impeachable under the Constitution
The 10-session day rule must be strictly complied with for verified complaints

“Our fundamental law is clear: the end does not justify the means.”

Key Constitutional Takeaways

No impeachment complaint against the same official can proceed within one year of a dismissed or lapsed complaint
The House must immediately include verified complaints in the Order of Business within 10 session days—no exceptions
Political will cannot override constitutional process
Impeachment requires both legal sufficiency and procedural fairness

Implications for Public Governance

The ruling preserves the sanctity of due process in high-level political accountability, setting precedent for all future impeachment proceedings. This is a stern reminder that constitutional safeguards cannot be bypassed for expedience or political convenience.

“We cannot concede the sobriety of fairness inherent in due process of law to the passions of a political moment.”

Related Cases

G.R. No. 278353 – Sara Z. Duterte v. House of Representatives
G.R. No. 278359 – Atty. Israelito P. Torreon et al. v. House of Representatives et al.

Decisions will be uploaded on the Supreme Court website upon final release.

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