I. Introduction

The impeachment process occupies a critical intersection between law and politics in the Philippines. It is a constitutional mechanism designed to ensure accountability among the highest officials of the land, such as the President, Vice President, Members of the Supreme Court, and Constitutional Commissions. However, when the judiciary, particularly the Supreme Court, intervenes in impeachment proceedings, the boundaries between judicial review and political discretion blur. This raises the perennial question: Did the Supreme Court overreach its constitutional mandate by intervening in impeachment cases?

II. Constitutional Framework of Impeachment

The 1987 Philippine Constitution establishes impeachment as both a political and constitutional process. Articles XI, Sections 2–3 provide that certain high-ranking officials “may be removed from office on impeachment for, and conviction of, culpable violation of the Constitution, treason, bribery, graft and corruption, other high crimes, or betrayal of public trust.”

The House of Representatives has the exclusive power to initiate impeachment proceedings (Art. XI, Sec. 3[1]), while the Senate has the sole power to try and decide impeachment cases (Sec. 3[6]). These exclusive powers have traditionally been viewed as political prerogatives insulated from judicial interference — a doctrine that preserves the separation of powers.

III. Judicial Review and Political Questions

The doctrine of separation of powers implies that each branch of government is supreme within its own sphere. However, the judiciary retains the power of judicial review — the authority to determine whether acts of government conform to the Constitution (Art. VIII, Sec. 1).

A related doctrine, the political question doctrine, traditionally limits judicial review in areas committed by the Constitution to the discretion of the political branches. However, the 1987 Constitution significantly expanded judicial power, mandating courts to determine whether there has been a grave abuse of discretion amounting to lack or excess of jurisdiction by any branch or instrumentality of the government. This clause has been pivotal in the Supreme Court’s intervention in impeachment controversies.

IV. Key Jurisprudence

1. Francisco v. House of Representatives (G.R. No. 160261, November 10, 2003)

This landmark case arose from the attempt to impeach Chief Justice Hilario Davide Jr. twice within one year. The Court ruled that the second impeachment complaint was barred under the one-year rule (Art. XI, Sec. 3[5]).

In doing so, the Court asserted its authority to review acts of Congress in impeachment proceedings when there is an allegation of grave abuse of discretion. It reasoned that the House’s exclusive power to initiate impeachment does not place it beyond the reach of constitutional limits.

However, critics argue that this decision judicialized a political process, undermining the independence of the legislature and setting a precedent for judicial encroachment on political functions.

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

Former Ombudsman Merceditas Gutierrez sought to halt impeachment proceedings against her, invoking Francisco. The Court initially issued a status quo ante order, but eventually dismissed the petition, upholding the proceedings.

While reaffirming Francisco, the Court clarified that judicial review in impeachment matters is not absolute — it may only intervene to correct grave abuse of discretion, not mere errors in judgment. The ruling emphasized judicial restraint but did not fully dispel concerns about the judiciary’s power to halt political proceedings.

3. Sereno v. Committee on Justice and House of Representatives (2018)

In a controversial twist, Chief Justice Maria Lourdes Sereno questioned the impeachment proceedings against her. However, the Court later ousted her not through impeachment, but through quo warranto (Republic v. Sereno, G.R. No. 237428, May 11, 2018*).

This decision reignited debates about the limits of judicial power. Critics argued that the Court circumvented the impeachment process — the exclusive constitutional mechanism for removing a sitting Chief Justice — thereby committing judicial overreach and weakening institutional checks and balances.

V. Arguments on Judicial Overreach

A. In Favor of Judicial Review

Constitutional Supremacy: Judicial review ensures that all branches remain within constitutional bounds.
Grave Abuse of Discretion Clause: The 1987 Constitution explicitly allows courts to check any government act tainted by grave abuse, even those previously labeled as political questions.
Rule of Law: The judiciary serves as the final arbiter of constitutional disputes, ensuring procedural regularity in impeachment.

B. Against Judicial Intervention

Violation of Separation of Powers: The impeachment process, being political, is constitutionally reserved for Congress.
Chilling Effect: Judicial interference may deter legitimate political accountability efforts.
Erosion of Legislative Independence: The Court’s willingness to intervene undermines the autonomy of the political branches.

VI. Comparative Perspective

In the United States, from which the Philippine impeachment model is derived, courts have consistently refused to intervene in impeachment proceedings (Nixon v. United States, 506 U.S. 224 [1993]*), classifying them as non-justiciable political questions. The Philippine Supreme Court’s departure from this approach underscores a unique constitutional evolution shaped by its post-authoritarian commitment to judicial oversight.

VII. Evaluating the Alleged Overreach

Whether the Supreme Court overreached depends on one’s interpretive lens:

Textualists argue that the Constitution’s expansion of judicial power justifies intervention in cases of grave abuse, preserving constitutional supremacy.
Structuralists and political realists, however, contend that the Court’s actions, particularly in Francisco and Sereno, blur the constitutional demarcation between law and politics, threatening institutional balance.

Thus, while the judiciary’s interventions were legally grounded, they may have been politically imprudent, revealing the tension between constitutional guardianship and judicial restraint.

VIII. Conclusion

The Philippine Supreme Court’s involvement in impeachment cases has redefined the contours of judicial review and justiciability. While intended to uphold constitutional fidelity, such interventions risk transforming the Court into an arbiter of political conflicts rather than a guardian of legal principles.

Ultimately, the question is not merely whether the Court can review impeachment proceedings, but whether it should. The preservation of democratic equilibrium demands both constitutional vigilance and institutional humility — a reminder that even the highest court must exercise its power with restraint, lest it erode the very balance it seeks to protect.