Supreme Court Clarifies One-Year Bar Rule in Impeachment Proceedings

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 Supreme Court Clarifies One-Year Bar Rule in Impeachment Proceedings

Gutierrez v. House of Representatives Committee on Justice, G.R. No. 193459 | February 15, 2011

By Atty. Phil Juris 
Published: June 12, 2025

MANILA, Philippines — In a landmark ruling that has since become a cornerstone in constitutional law and bar examinations, the Supreme Court clarified the meaning of "initiation" in impeachment proceedings under the 1987 Constitution, settling a critical issue in Gutierrez v. House of Representatives Committee on Justice (G.R. No. 193459, February 15, 2011).

At the center of the case was then-Ombudsman Ma. Merceditas N. Gutierrez, who in 2010 faced two impeachment complaints filed just months apart before the House of Representatives. She sought to halt the second complaint, citing the constitutional prohibition against initiating more than one impeachment proceeding against the same official within a one-year period.

Gutierrez argued that the first complaint already triggered this one-year bar the moment it was filed. However, the House of Representatives maintained that impeachment is only initiated once the complaint is not just filed but also referred to the Committee on Justice.

Constitutional Question Addressed

The Supreme Court, sitting en banc, resolved the key issue: When is an impeachment proceeding considered “initiated” under the one-year bar rule of Article XI, Section 3(5) of the Constitution?

The Constitution provides:

“No impeachment proceedings shall be initiated against the same official more than once within a period of one year.”
— Art. XI, Sec. 3(5), 1987 Constitution

In its ruling, the Court held that the “initiation” of impeachment proceedings requires both the filing of the complaint and its referral to the House Committee on Justice.

Filing Alone Is Not Enough

The Court reaffirmed its earlier doctrine in Francisco v. House of Representatives, emphasizing that mere filing does not trigger the one-year bar. The process must include the formal referral by the House, which constitutes the body's first official action to act on the complaint.

“Initiation starts with the filing of the complaint which must be accompanied with an action to set the complaint moving... The initial action taken by the House is the referral of the complaint to the Committee on Justice,” the Court wrote.

As applied to Gutierrez’s case, both impeachment complaints against her were filed and referred to the Committee within a short timeframe in 2010. Since the first complaint had already been referred, the referral of the second complaint violated the constitutional safeguard and was deemed invalid.

Doctrine Solidified: One-Year Bar Starts from Referral

The ruling established a crucial procedural guardrail: once a complaint is filed and referred, Congress cannot entertain any other impeachment case against the same official within the next 12 months. This interpretation aims to protect constitutional officers from harassment via serial or overlapping complaints.

Legal experts view the decision as a reinforcement of the balance between accountability and stability in high public office. “This ruling ensures that while officials remain answerable to the people, they are not made vulnerable to political persecution through repeated impeachment attempts,” one professor of constitutional law noted.

Relevance to Legal Practice and Bar Exams

Gutierrez v. House Committee on Justice remains a fixture in bar review materials, often cited in discussions on impeachment, separation of powers, and constitutional interpretation.

Law students are advised to remember the “two-step rule”—filing plus referral—as the correct standard for determining when impeachment proceedings are officially initiated.

Takeaway for Legislators and Citizens

With impeachment continuing to be a potent political and legal tool, the Supreme Court’s guidance in this case offers clarity: the process must follow constitutional procedures to be valid. The ruling curbs possible abuses while respecting the mandate of Congress to check public officers when warranted.

In the years since Gutierrez, this ruling has helped ensure that the impeachment process remains a constitutional mechanism—not a weapon.


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