THE SUPREME COURT RULING ON VP SARAH DUTERTE'S IMPEACHMENT

Supreme Court Bars Impeachment of VP Sara Duterte: One-Year Rule & COA Audit Context

In a unanimous decision, the Supreme Court of the Philippines declared the impeachment complaint against Vice President Sara Duterte unconstitutional, effectively stopping the impeachment process before the Senate could take jurisdiction.

The ruling immediately halted what would have been one of the most consequential political accountability proceedings in recent Philippine history, raising fundamental questions about constitutional limits, due process, and judicial oversight.

Supreme Court of the Philippines building
The Supreme Court ruled that the impeachment complaint was unconstitutional from the outset.

The One-Year Bar on Impeachment Proceedings

The Court’s primary basis for invalidating the impeachment complaint was the violation of the Constitution’s one-year prohibition on successive impeachment proceedings.

Article XI, Section 3(5) of the 1987 Constitution states that no impeachment proceedings shall be initiated against the same official more than once within a one-year period.

The Court ruled that although three earlier impeachment complaints were not acted upon by the House of Representatives, they nonetheless constituted the initiation of impeachment proceedings once filed.

Why the Fourth Complaint Was Barred

Four impeachment complaints were filed against Vice President Duterte between December 2024 and February 2025. The first three were eventually archived or dismissed when Congress adjourned.

The fourth complaint, endorsed by more than one-third of House members and transmitted to the Senate on February 5, 2025, was filed within one year of the earlier complaints. As a result, it was already constitutionally barred under the one-year rule.

House of Representatives of the Philippines
The House endorsement could not override constitutional limits on impeachment.

Due Process and Procedural Fairness

In addition to the one-year bar, the Court cited due process concerns. While impeachment is a political mechanism, the Court emphasized that it must still comply with constitutional standards of fairness and procedural clarity.

The ruling underscored that political urgency or majority support cannot justify ignoring constitutional safeguards.

Senate Jurisdiction and Legal Reality

Because the impeachment complaint was unconstitutional at its inception, the Senate could not validly acquire jurisdiction to conduct a trial. In constitutional law, a defect at the source cannot be cured by later actions in the process.

What the Ruling Does - and Does Not - Accomplish

The Supreme Court clarified that the decision does not absolve Vice President Duterte of the allegations raised against her. A new impeachment complaint may still be filed, but only after February 6, 2026, once the one-year bar has elapsed.

Commission on Audit Findings on OVP Funds

One of the central public arguments supporting impeachment was the allegation that the Office of the Vice President (OVP) had misused government funds. However, the Commission on Audit’s most recent audit for 2024 shows a different picture.

The COA issued an “unmodified opinion” on the OVP’s financial statements for 2024, indicating they were presented fairly in all material respects according to applicable accounting standards. The OVP itself stated that the COA’s audit showed “no findings of loss or wastage of government funds or property”, and that most issues were administrative in nature and agreed to be addressed by management.

An unmodified audit opinion is the highest level of assurance on financial statements and suggests that, at minimum, there was no evidence of material misstatement in how funds were recorded and reported.

This does not mean that every procedural audit observation was without concern, and COA and other observers have noted that an unmodified opinion does not automatically equate to a complete absence of issues.

Still, given how central allegations of misuse were to public debate, these audit findings weaken the narrative that there was clear evidence of improper fund use by the OVP based solely on audit outcomes.

Public and Legal Reactions

Supporters of the ruling praised it as a defense of constitutional limits and protection against political harassment. Critics, however, warned that the decision could weaken accountability and enable strategic use of procedural rules to shield officials. The ruling has sparked renewed debate about the balance between judicial review and congressional authority in impeachment cases.

Why This Decision Matters

The case sets a powerful precedent for future impeachment efforts. It reinforces the Supreme Court’s role as the final interpreter of constitutional boundaries, even in politically sensitive disputes. Whether the ruling ultimately strengthens democratic stability or constrains accountability remains a subject of intense public debate.

References & Further Reading

  • 1987 Philippine Constitution, Article XI
  • Supreme Court En Banc Decision, July 25, 2025
  • COA 2024 Annual Audit Report statements on OVP audit findings
  • Public statements by the Office of the Vice President on COA audit results
© 2026 • ET PLUSarticles. All rights reserved | Law / Politics

Ulysses C. Ybiernas

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