SARA Z. DUTERTE, IN HER CAPACITY AS THE VICE PRESIDENT OF THE PHILIPPINES, PETITIONER, VS. HOUSE OF REPRESENTATIVES, REPRESENTED BY FERDINAND MARTIN G. ROMUALDEZ, IN HIS CAPACITY AS THE SPEAKER OF THE HOUSE OF REPRESENTATIVES, REGINALDO S. VELASCO, IN HIS CAPACITY AS THE SECRETARY-GENERAL OF THE…
- G.R. Number: G.R. No. 278353
- Promulgated: 2025-07-25
- Ponente: LEONEN, SAJ.
Doctrine
## Facts of the Case On December 2, 2024, private individuals and organizations filed the first impeachment complaint against Vice President Sara Z. Duterte (Petitioner Duterte) with the House of Representatives, alleging graft and corruption, betrayal of public trust, and high crimes. This was followed by a second impeachment complaint on December 4, 2024, focused on alleged misuse of confidential funds, and a third on December 19, 2024, concerning plunder and graft related to confidential funds. All three complaints were filed under Article XI, Section 3(2) of the Constitution and endorsed by House members. Despite the constitutional mandate for complaints to be included in the Order of Business within 10 session days and referred to the Committee on Justice within three session days, the House did not act on these complaints until February 5, 2025. On the same day, a fourth impeachment complaint was filed against Vice President Duterte by 215 members of the House under Article XI, Section 3(4), which, upon meeting the one-third vote threshold, constituted the Articles of Impeachment. The charges included corruption, an assassination threat against the President, and incitement to insurrection. The Articles of Impeachment were transmitted to the Senate that same day, February 5, 2025, without a plenary vote. On February 18, 2025, Vice President Duterte and a group of lawyers (Torreon et al.) filed separate Petitions for Certiorari and Prohibition with the Supreme Court, challenging the constitutionality of the fourth impeachment complaint, citing violations of the one-year bar rule and due process. The Senate, meanwhile, began preparations for the impeachment trial but subsequently voted to return the case to the House to clarify the constitutionality of its formation. Vice President Duterte filed an Answer Ad Cautelam with the Senate, reiterating her arguments from the Supreme Court petitions. The Supreme Court issued a Resolution on July 8, 2025, directing the parties to submit additional documents and information regarding the impeachment proceedings. ## Issues 1. Can the Supreme Court exercise its power of judicial review over the nature of impeachment proceedings under Article VIII, Section 1 of the Constitution? 2. Are impeachment proceedings legal and constitutional procedures subject to judicial review by the Supreme Court? 3. Did the House of Representatives comply with the requirements of Article XI, Section 3(2) of the Constitution regarding the three initial impeachment complaints, specifically on referral to the proper committee? 4. Did the House of Representatives commit grave abuse of discretion in verifying the fourth impeachment complaint and transmitting the Articles of Impeachment to the Senate? 5. Is the fourth impeachment complaint unconstitutional due to a violation of the one-year bar rule under Article XI, Section 3(5) of the Constitution? 6. Did the fourth impeachment complaint violate Vice President Duterte's constitutional right to due process and speedy disposition of cases under Article III of the Constitution? ## Decision / Rationale **Issue 1 & 2:** The Court ruled that **judicial power includes the duty to determine grave abuse of discretion** by any branch of government, including co-equal branches. Impeachment proceedings are primarily **legal and constitutional procedures**, although they occur within a political environment. They are not purely political and are therefore **subject to judicial review**, especially concerning legal issues and strict adherence to constitutional frameworks. While the Court does not determine the outcome or merits of an impeachment, it has the duty to construe the process mandated by the Constitution. An **actual case or controversy** exists when there is a conflict of legal rights that can be interpreted and enforced, or a clear and convincing demonstration of a contrariety of legal rights. Both **as-applied** and **facial challenges** can be brought, with…
Keywords
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