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Updated 2nd February 2025
Gutierrez vs. The House of Representatives Committee on Justice, Hontiveros-Baraquel, et al.
The Supreme Court denied petitioner Ombudsman Ma. Merceditas Gutierrez’s motion for reconsideration, reaffirming that the initiation of impeachment proceedings under the Constitution requires both filing and referral of a complaint to the House Committee on Justice. The Court ruled that the “one-year bar” on impeachment proceedings begins upon the House’s referral, not mere filing, thereby dismissing Gutierrez’s claim of procedural violation.

Primary Holding

Impeachment proceedings are “initiated” when a complaint is filed and referred to the House Committee on Justice, triggering the constitutional one-year bar against subsequent proceedings.

Background

Gutierrez faced two impeachment complaints filed 11 days apart in 2010. The House referred both to its Committee on Justice. Gutierrez argued this violated the constitutional prohibition against multiple proceedings within one year.

History

  • September 14, 2010: Supreme Court issued a Status Quo Ante Order halting House proceedings.

  • February 15, 2011: Court lifted the order and upheld the House’s actions.

  • March 8, 2011: Motion for reconsideration denied.

Facts

  • 1. Two impeachment complaints were filed against Gutierrez (July 22 and August 3, 2010). The House referred both to its Committee, which consolidated them. Gutierrez argued this violated the one-year bar under Article XI, Section 3(5) of the Constitution.

Arguments of the Petitioners

  • 1. Initiation of impeachment starts at filing; the second complaint violated the one-year bar.
  • 2. House Impeachment Rules required publication to be valid.
  • 3. The Committee Chairperson exhibited bias.

Arguments of the Respondents

  • 1. Initiation requires filing and referral.
  • 2. Publication of House Impeachment Rules is unnecessary.
  • 3. Impeachment is a political process, and courts must defer to Congress’ discretion.

Issues

  • 1. Does “initiation” of impeachment proceedings under Article XI, Section 3(5) of the Constitution begin at filing or referral?
  • 2. Must House Impeachment Rules be published?
  • 3. Did the Committee Chairperson’s actions demonstrate bias?

Ruling

  • 1. Initiation requires filing and referral, barring multiple proceedings within a year.
  • 2. Publication of House Impeachment Rules is not required; “promulgate” in the Constitution means internal adoption.
  • 3. Allegations of bias were unfounded, as impeachment is political and collective.

Doctrines

  • 1. Francisco Jr. v. House of Representatives: Initiation involves filing and referral.
  • 2. Tañada v. Tuvera: Distinguished; publication not required for impeachment rules.

Key Excerpts

  • 1. “[Initiation] includes the Houses initial action on the complaint.”
  • 2. “Impeachment is a highly politicized intramural that gives the House ample leg room.”

Precedents Cited

  • 1. Francisco Jr. v. House of Representatives: Defined initiation as filing and referral.
  • 2. Neri v. Senate: Contrasted publication requirements for legislative inquiries vs. impeachment rules.
  • 3. Tañada v. Tuvera: Limited to general publication rules, not impeachment.

Statutory and Constitutional Provisions

  • 1. Art. XI, Sec. 3(2): Powers of the House in impeachment.
  • 2. Art. XI, Sec. 3(4): Filing requirements.
  • 3. Art. XI, Sec. 3(8): House’s authority to promulgate impeachment rules.