I. Overview

In the Philippine constitutional system, impeachment is not an ordinary civil, criminal, or administrative case. It is a special constitutional process entrusted primarily to Congress. The House of Representatives has the exclusive power to initiate impeachment cases, while the Senate has the sole power to try and decide them.

Because impeachment is constitutionally assigned to political departments, a Regional Trial Court generally has no jurisdiction to initiate, stop, review, reverse, supervise, or interfere with impeachment proceedings. An RTC cannot try an impeachment complaint, cannot enjoin the House from acting on impeachment, cannot restrain the Senate from conducting an impeachment trial, and cannot rule on the guilt or innocence of an impeachable officer.

The jurisdiction of courts over impeachment-related controversies is extremely limited. If judicial review is available at all, it is usually through the Supreme Court, not the RTC, and only where there is a proper justiciable issue such as grave abuse of discretion, violation of constitutional limitations, or breach of due process.

II. Constitutional Basis of Impeachment in the Philippines

Impeachment is governed by Article XI of the 1987 Constitution, titled “Accountability of Public Officers.”

The Constitution provides that certain high-ranking public officials may be removed from office only by impeachment. These include:

the President;
the Vice-President;
members of the Supreme Court;
members of the Constitutional Commissions;
the Ombudsman.

These are commonly called impeachable officers.

The grounds for impeachment are:

culpable violation of the Constitution;
treason;
bribery;
graft and corruption;
other high crimes;
betrayal of public trust.

The purpose of impeachment is not ordinary punishment in the criminal-law sense. Its direct constitutional consequence is removal from office and possible disqualification from holding public office. Criminal, civil, or administrative liability may still follow separately after impeachment, depending on the facts and applicable law.

III. Nature of Impeachment

Impeachment is often described as a political process with legal features. It is political because it concerns the removal of high constitutional officers and is assigned to Congress. It is legal because it is governed by the Constitution, must observe constitutional limits, and may involve legal questions.

It is not the same as:

a criminal prosecution;
a civil action;
an administrative disciplinary case;
an election protest;
a quo warranto case;
a petition for injunction in a trial court.

Because it is sui generis, or one of a kind, ordinary rules on trial court jurisdiction do not apply in the same way they apply to civil or criminal actions.

IV. Exclusive Role of the House of Representatives

The House of Representatives has the exclusive power to initiate all cases of impeachment.

This means that the filing, referral, evaluation, committee proceedings, approval, dismissal, or transmission of impeachment complaints belong to the constitutional domain of the House.

The House acts through its constitutionally authorized mechanisms, such as:

filing of a verified impeachment complaint;
endorsement by members of the House where required;
referral to the proper committee;
committee determination of sufficiency in form and substance;
committee hearings;
voting by the House;
approval of articles of impeachment;
transmission to the Senate.

An RTC cannot substitute its judgment for the House in deciding whether a complaint is sufficient in form, sufficient in substance, politically persuasive, supported by evidence, or worthy of trial.

V. Exclusive Role of the Senate

The Senate has the sole power to try and decide all cases of impeachment.

When the House transmits articles of impeachment, the Senate sits as an impeachment court. Senators take an oath or affirmation, and the Senate receives evidence, hears arguments, rules on incidents, and votes on conviction or acquittal.

When the President is on trial, the Chief Justice of the Supreme Court presides, but the Chief Justice does not become the judge of guilt or innocence. The Senate remains the impeachment court.

An RTC cannot:

take jurisdiction over the trial;
issue an injunction against the Senate impeachment court;
compel senators to vote a certain way;
review Senate evidentiary rulings;
declare an impeachment trial void while it is ongoing;
reverse a conviction or acquittal;
order reinstatement based on disagreement with the Senate’s judgment.

VI. General Rule: RTCs Have No Jurisdiction Over Impeachment Proceedings

The general rule is straightforward: Regional Trial Courts have no jurisdiction over impeachment proceedings.

This is because RTC jurisdiction is statutory and constitutional. RTCs may exercise only the jurisdiction granted by law. Impeachment, however, is assigned by the Constitution to the House and the Senate, not to trial courts.

A Regional Trial Court is a court of general jurisdiction for many ordinary civil and criminal cases, but it is not a constitutional impeachment tribunal. No statute can validly confer upon an RTC the power to try an impeachment case, because the Constitution itself assigns that role to the Senate. Likewise, no RTC can initiate impeachment because the Constitution assigns that role to the House.

VII. Why RTC Jurisdiction Is Excluded

RTC jurisdiction over impeachment is excluded for several reasons.

First, the Constitution uses exclusive language. The House has the exclusive power to initiate impeachment, and the Senate has the sole power to try and decide impeachment cases.

Second, impeachment is a constitutional check lodged in Congress. Allowing an RTC to control impeachment would disrupt the separation of powers.

Third, impeachment involves officers of the highest constitutional rank. It would be structurally inconsistent for a trial court judge to halt or command proceedings constitutionally assigned to Congress.

Fourth, impeachment decisions may involve political questions, institutional judgment, and constitutional discretion.

Fifth, judicial review of impeachment-related questions, when proper, is generally lodged in the Supreme Court under its expanded power to determine grave abuse of discretion by any branch or instrumentality of government.

VIII. Separation of Powers

The doctrine of separation of powers divides governmental authority among the legislative, executive, and judicial branches.

Impeachment is one of the Constitution’s mechanisms for accountability among coordinate branches. The House accuses; the Senate tries; the impeached official answers.

If RTCs could interfere with impeachment proceedings, trial courts could effectively control Congress in the exercise of a power expressly granted by the Constitution. This would create a serious separation-of-powers problem.

The courts may interpret the Constitution, but they cannot assume powers textually committed to another branch. In impeachment, the Constitution commits initiation to the House and trial to the Senate.

IX. Political Question Doctrine

The political question doctrine limits judicial intervention where the Constitution commits a matter to another branch, or where there are no manageable judicial standards for resolving the issue.

Impeachment has political-question elements because it involves the constitutional judgment of Congress on whether an impeachable officer should be removed.

However, Philippine constitutional law recognizes an expanded judicial power: courts may determine whether any branch or instrumentality committed grave abuse of discretion amounting to lack or excess of jurisdiction.

Even so, this does not mean every court may interfere. In practice, impeachment-related constitutional challenges belong primarily to the Supreme Court, not the RTC.

X. The Supreme Court’s Limited Role

The Supreme Court may review certain impeachment-related controversies if a proper case is brought before it. This does not mean the Supreme Court may try the impeachment case itself. It means the Court may determine whether constitutional boundaries were violated.

Examples of issues that may possibly be reviewed by the Supreme Court include:

whether the one-year impeachment bar was violated;
whether the constitutional vote requirement was ignored;
whether the House or Senate committed grave abuse of discretion;
whether a constitutional officer’s right to due process was violated;
whether an impeachment complaint was initiated in a constitutionally invalid manner;
whether the Senate acted beyond its constitutional authority.

The Supreme Court’s role is supervisory in the constitutional sense, not substitutive. It does not become the impeachment court.

XI. RTC Versus Supreme Court Jurisdiction

The distinction between RTC jurisdiction and Supreme Court jurisdiction is critical.

An RTC may hear ordinary civil and criminal cases within its statutory jurisdiction. But impeachment proceedings are not ordinary cases. They are constitutional proceedings assigned to Congress.

The Supreme Court, on the other hand, has constitutional judicial power, including the authority to determine whether any branch or instrumentality committed grave abuse of discretion.

Thus, if a party believes that Congress violated the Constitution in impeachment proceedings, the proper remedy is generally not an RTC injunction case but a petition invoking the Supreme Court’s constitutional power, usually through extraordinary remedies such as certiorari, prohibition, or mandamus where appropriate.

XII. Can an RTC Issue an Injunction Against Impeachment Proceedings?

As a general rule, no.

An RTC cannot validly issue an injunction to stop the House from processing an impeachment complaint or to stop the Senate from conducting an impeachment trial. Such an injunction would interfere with constitutional powers exclusively assigned to Congress.

A complaint filed in an RTC seeking to enjoin impeachment proceedings would usually be vulnerable to dismissal for lack of jurisdiction, improper remedy, violation of separation of powers, and failure to state a cause of action within the RTC’s competence.

Even if the complaint is framed as one for declaratory relief, injunction, prohibition, or damages, the substance controls. If the real objective is to control impeachment proceedings, an RTC should not take jurisdiction.

XIII. Can an RTC Declare an Impeachment Complaint Invalid?

Generally, no.

An RTC cannot declare an impeachment complaint invalid if doing so would interfere with the House’s constitutional power to initiate impeachment. The sufficiency, referral, and processing of impeachment complaints are matters internal to the House, subject only to constitutional limits.

A party challenging the validity of an impeachment complaint on constitutional grounds should ordinarily proceed before the Supreme Court, not an RTC.

XIV. Can an RTC Stop the Senate Impeachment Trial?

No.

The Senate has the sole power to try and decide impeachment cases. An RTC cannot stop the Senate impeachment court from hearing evidence, ruling on motions, issuing subpoenas, or voting on the articles of impeachment.

A trial court order attempting to restrain the Senate impeachment court would be constitutionally suspect and likely void for lack of jurisdiction.

XV. Can an RTC Review the Senate’s Judgment?

No.

An RTC cannot review, reverse, modify, or annul a Senate judgment in an impeachment case. The Senate’s power to try and decide impeachment is constitutionally conferred.

Whether the Supreme Court may review aspects of an impeachment judgment is a separate and exceptional question. But an RTC is not the reviewing body.

XVI. Can an RTC Hear a Criminal Case Related to the Same Facts?

Yes, but only separately and only if jurisdiction otherwise exists.

Impeachment does not necessarily bar criminal prosecution. The Constitution contemplates that an impeached and convicted officer may still be liable and subject to prosecution, trial, and punishment according to law.

However, criminal liability is distinct from impeachment liability.

For example, if the facts alleged in impeachment also constitute bribery, graft, falsification, plunder, or another criminal offense, the proper criminal case may be filed before the court with jurisdiction after the applicable legal requirements are met. Depending on the offense and accused, jurisdiction may belong to the Sandiganbayan or regular courts, not necessarily the RTC.

The RTC may hear a related criminal case only if the law gives it jurisdiction over that offense and accused. It still cannot use the criminal case as a vehicle to control the impeachment proceeding.

XVII. Can an RTC Hear a Civil Case Related to the Same Facts?

Possibly, but not if the case seeks to control impeachment.

An RTC may have jurisdiction over ordinary civil actions, such as damages, property disputes, or enforcement of private rights, if the requisites of jurisdiction are present. But if the civil action’s real purpose is to suspend, derail, invalidate, or influence impeachment, the RTC should decline jurisdiction.

For example:

A private defamation suit arising from statements made outside privileged proceedings may raise ordinary civil-law issues.
A damages case based on unrelated private acts may proceed if jurisdiction exists.
A petition asking the RTC to stop the House from transmitting articles of impeachment should not proceed.

The controlling test is the nature and effect of the action.

XVIII. Can an RTC Compel Congress to Act on an Impeachment Complaint?

Generally, no.

An RTC cannot compel the House to act on, dismiss, approve, calendar, or transmit an impeachment complaint. Internal congressional proceedings are governed by the Constitution and House rules.

A mandamus action in an RTC against Congress involving impeachment would raise serious jurisdictional and separation-of-powers defects.

If there is a clear constitutional duty and grave abuse is alleged, the proper forum would ordinarily be the Supreme Court.

XIX. Declaratory Relief and Impeachment

Declaratory relief is an ordinary civil remedy used to determine rights under a deed, will, contract, statute, executive order, regulation, ordinance, or other written instrument before breach or violation.

It is not generally an appropriate RTC device to control impeachment proceedings. A petition for declaratory relief asking an RTC to interpret impeachment rules in order to stop the House or Senate would likely fail because impeachment is constitutionally committed to Congress and because the case would involve political and constitutional questions beyond RTC interference.

Where the issue is constitutional and directed against acts of Congress in impeachment, the Supreme Court is the more appropriate forum.

XX. Certiorari, Prohibition, and Mandamus

The remedies commonly discussed in impeachment-related litigation are certiorari, prohibition, and mandamus.

Certiorari may be used to challenge acts allegedly done with grave abuse of discretion amounting to lack or excess of jurisdiction.

Prohibition may seek to prevent a tribunal, board, officer, or person from proceeding without or in excess of jurisdiction.

Mandamus may compel performance of a ministerial duty.

Although RTCs may have jurisdiction over certain petitions for certiorari, prohibition, and mandamus against lower tribunals, officers, or boards in ordinary cases, impeachment proceedings are different. A petition seeking to restrain or command the House or Senate in impeachment matters implicates coordinate constitutional branches and should generally be brought before the Supreme Court.

XXI. The One-Year Bar Rule

One of the most important constitutional limitations on impeachment is the rule that no impeachment proceedings shall be initiated against the same official more than once within a period of one year.

Disputes may arise as to when impeachment is “initiated.” This is a constitutional question that may affect the validity of subsequent complaints.

An RTC should not be the forum to resolve such a question if the relief sought is to stop or invalidate congressional impeachment proceedings. Such a matter belongs, if at all, to the Supreme Court.

XXII. Due Process in Impeachment

Impeachment proceedings must observe due process, although the exact contours of due process in impeachment may differ from ordinary criminal trials.

Due process may involve:

notice of charges;
opportunity to respond;
fair hearing;
reasonable rules of procedure;
impartiality to the extent constitutionally required;
adherence to constitutional voting requirements.

But due process claims do not automatically create RTC jurisdiction. If an impeachable officer claims denial of due process in impeachment proceedings, the remedy is generally not to ask an RTC to stop Congress, but to invoke the proper constitutional remedy before the Supreme Court.

XXIII. Internal Rules of Congress

Both the House and Senate may adopt rules governing impeachment proceedings.

The House may adopt rules for filing, referral, committee proceedings, and approval of impeachment complaints.

The Senate may adopt rules for impeachment trial, presentation of evidence, motions, subpoenas, and voting.

Courts are generally reluctant to interfere with internal congressional rules unless there is a clear constitutional violation. RTCs, in particular, should not police the internal rules of impeachment because doing so would intrude upon legislative autonomy.

XXIV. Judicial Review Is Not the Same as Trial Court Interference

It is important to distinguish between two ideas:

Judicial review of constitutional violations, which may be available in exceptional cases; and
Trial court interference with impeachment, which is generally impermissible.

The Supreme Court may determine whether constitutional limits were exceeded. But that does not mean RTCs may issue temporary restraining orders, injunctions, or declarations against the House or Senate regarding impeachment.

The Constitution’s expanded judicial power prevents unchecked grave abuse. It does not convert RTCs into impeachment supervisors.

XXV. Impeachment and Quo Warranto

A quo warranto proceeding is different from impeachment.

Impeachment removes an impeachable officer for constitutional grounds after proceedings in Congress. Quo warranto questions a person’s legal right or title to hold office.

The relationship between impeachment and quo warranto has been controversial in Philippine constitutional law, especially where the officer involved is an impeachable officer. The key distinction is that impeachment assumes the officer is occupying the office but seeks removal for impeachable offenses, while quo warranto challenges the validity of the officer’s title to office.

An RTC generally does not acquire jurisdiction over impeachment simply because a pleading is styled as quo warranto. Jurisdiction depends on the nature of the action, the office involved, the relief sought, and the law conferring jurisdiction.

XXVI. Impeachment and Administrative Cases

Impeachable officers cannot generally be removed from office through ordinary administrative proceedings if the act would effectively bypass the impeachment mechanism. The Constitution protects certain officials from removal except by impeachment.

This does not mean they are above the law. It means that while they hold office, removal must follow the constitutional method.

An RTC cannot convert an impeachment matter into an administrative case to remove an impeachable officer.

XXVII. Impeachment and Criminal Prosecution Before Removal

A difficult issue is whether an impeachable officer may be criminally prosecuted while still in office. The answer may depend on the office, the offense, immunity rules, and applicable jurisprudence.

The President enjoys special constitutional immunity from suit during tenure as recognized in Philippine law. Other impeachable officers may not enjoy the same breadth of immunity, but removal from office itself must occur through impeachment.

Even where criminal proceedings may be possible, the RTC’s criminal jurisdiction does not become jurisdiction over impeachment. A criminal court determines criminal liability; the Senate determines impeachment liability.

XXVIII. Can a Private Citizen File an RTC Case About Impeachment?

A private citizen may file cases in court only where there is a legal cause of action and the court has jurisdiction.

A citizen cannot ask an RTC to:

compel the House to impeach;
prohibit the Senate from trying impeachment;
declare an impeachment complaint sufficient or insufficient;
remove an impeachable officer through trial court order;
review congressional votes;
supervise impeachment procedure.

A citizen may, however, submit an impeachment complaint in accordance with constitutional and House rules, subject to endorsement and procedural requirements. The remedy is political-constitutional, not an RTC lawsuit.

XXIX. Temporary Restraining Orders Against Impeachment

A temporary restraining order issued by an RTC against impeachment proceedings would be highly vulnerable to challenge.

The reasons include:

lack of jurisdiction;
violation of separation of powers;
improper interference with Congress;
absence of statutory authority;
constitutional exclusivity of House and Senate powers;
availability of remedies before the Supreme Court for constitutional questions.

Even if irreparable injury is alleged, the nature of the proceeding matters. An RTC cannot create jurisdiction by invoking equity.

XXX. Contempt Powers and Impeachment Proceedings

The Senate impeachment court may exercise powers necessary to conduct trial proceedings, including issuing subpoenas and enforcing attendance, subject to constitutional limitations.

An RTC should not interfere with the Senate’s management of its impeachment trial. Disputes over subpoenas, evidence, or procedure in impeachment are normally resolved within the impeachment court itself, subject only to extraordinary constitutional review in the proper forum.

XXXI. Practical Consequences of Filing in the Wrong Forum

A party who files an impeachment-related case in an RTC may face several consequences:

dismissal for lack of jurisdiction;
denial of injunctive relief;
delay in obtaining meaningful relief;
possible adverse rulings on forum shopping if related cases are filed elsewhere;
loss of time-sensitive remedies;
confusion between political remedies and judicial remedies.

Because impeachment moves according to constitutional and congressional timelines, filing in the wrong forum may be fatal to a litigant’s strategy.

XXXII. Proper Remedies Depending on the Issue

The correct remedy depends on the nature of the complaint.

If the issue is that an impeachable officer committed impeachable offenses, the remedy is to pursue impeachment through the House of Representatives.

If the issue is that the House or Senate violated the Constitution, the remedy may be an original action before the Supreme Court, if the requisites of judicial review are present.

If the issue is ordinary criminal liability, the matter should be brought before the proper prosecutorial and judicial authorities.

If the issue is civil liability unrelated to controlling impeachment, an ordinary civil case may be filed in the court with jurisdiction.

If the issue is administrative discipline of a non-impeachable officer, the remedy is before the appropriate administrative body.

XXXIII. Jurisdictional Test

A useful test is to ask: What is the real relief sought?

If the relief sought is to stop, compel, invalidate, supervise, or review impeachment proceedings, the RTC has no jurisdiction.

If the relief sought is to decide an ordinary civil or criminal issue independent of impeachment, the RTC may have jurisdiction if the law otherwise grants it.

If the relief sought is constitutional review of congressional action in impeachment, the matter generally belongs to the Supreme Court.

XXXIV. Examples

Example 1: RTC Case to Stop House Committee Hearings

A respondent in an impeachment complaint files a petition in an RTC asking the court to stop the House committee from hearing the complaint.

The RTC should dismiss or decline relief because the House has exclusive power to initiate impeachment.

Example 2: RTC Case to Stop Senate Trial

An impeached officer files an injunction case in an RTC to restrain the Senate impeachment court from proceeding.

The RTC has no jurisdiction because the Senate has the sole power to try and decide impeachment cases.

Example 3: RTC Damages Case Based on Private Acts

A private person sues another private person for damages arising from defamatory statements related to political accusations, but the case does not seek to stop impeachment.

The RTC may have jurisdiction if the elements of the civil action and jurisdictional amount are present.

Example 4: Criminal Case After Impeachment

An impeached and convicted officer is later prosecuted for graft based on the same facts.

The criminal case may proceed before the court with jurisdiction, but that court is not exercising impeachment jurisdiction.

Example 5: Supreme Court Petition Alleging One-Year Bar Violation

A party files a petition directly with the Supreme Court alleging that the House violated the constitutional one-year impeachment bar.

This may present a justiciable constitutional issue, depending on the facts and procedural requisites.

XXXV. Limits of RTC Power Even Under Expanded Judicial Review

The 1987 Constitution expanded judicial power to include review of grave abuse of discretion by any branch or instrumentality of government. However, this does not mean all courts can entertain all constitutional controversies in any form.

The hierarchy of courts, the nature of the respondent, the subject matter, the relief sought, and constitutional structure all matter.

Where the controversy directly involves impeachment proceedings of Congress, the Supreme Court is the proper constitutional forum. RTCs should not entertain such cases merely because they are courts of general jurisdiction.

XXXVI. Can Congress Ignore an RTC Order on Impeachment?

As a rule, court orders are entitled to respect. However, an order issued without jurisdiction is void. If an RTC issues an order interfering with impeachment proceedings, the affected parties may challenge it through appropriate remedies, including certiorari or prohibition before a higher court.

Congress should not lightly disregard judicial processes, but neither should a trial court assume powers the Constitution denies it. The proper course is to challenge the invalid order before the appropriate court.

XXXVII. Role of the Solicitor General and Government Counsel

Where impeachment-related litigation is filed, government counsel may appear depending on the parties and issues involved. If the case challenges acts of the House, Senate, or public officials, appropriate government legal representation may be required.

In cases involving constitutional questions of national importance, the Solicitor General may participate, especially where the validity of governmental action is involved.

This does not alter the jurisdictional rule: RTCs do not become impeachment courts.

XXXVIII. Impeachment Is Not a Matter of Venue

The problem is not merely venue. It is not that the case was filed in the wrong city or province. The deeper defect is lack of subject-matter jurisdiction.

Subject-matter jurisdiction is conferred by the Constitution or statute. It cannot be created by agreement, waiver, silence, urgency, public interest, or the seriousness of accusations.

Thus, even if all parties appear before an RTC, the RTC still cannot validly acquire jurisdiction over impeachment proceedings.

XXXIX. Effect of Participation in RTC Proceedings

If a party participates in an RTC case involving impeachment, that participation generally does not cure lack of subject-matter jurisdiction.

A court without jurisdiction cannot acquire it by consent. A party may raise lack of jurisdiction, and the court may dismiss the case when the defect appears.

XL. Impeachment and the Rule of Law

The absence of RTC jurisdiction does not mean impeachment is beyond law. Impeachment remains governed by the Constitution. The House and Senate must act within constitutional boundaries. Grave abuse of discretion may be reviewed in a proper case.

But the rule of law also requires respect for constitutional allocation of powers. Trial courts cannot assume functions assigned to Congress.

The proper balance is this:

Congress conducts impeachment.
The Supreme Court may review constitutional excesses in proper cases.
RTCs handle ordinary cases within their jurisdiction.
Criminal and civil liability may proceed separately where allowed by law.

XLI. Key Doctrines

The following doctrines summarize the subject:

Impeachment is a constitutional process. It is not an ordinary civil, criminal, or administrative case.
The House has exclusive power to initiate impeachment. RTCs cannot interfere with initiation.
The Senate has sole power to try and decide impeachment cases. RTCs cannot conduct or stop impeachment trials.
RTC jurisdiction is limited by law. It cannot be expanded by pleading labels.
The real nature of the action controls. A petition styled as injunction, declaratory relief, mandamus, or damages may still be improper if it seeks to control impeachment.
The Supreme Court may exercise limited constitutional review. Judicial review is possible only in proper cases involving grave abuse of discretion or constitutional violation.
Ordinary civil or criminal cases may proceed separately. But they must not be used to interfere with impeachment.
Subject-matter jurisdiction cannot be waived. Consent or participation cannot give an RTC impeachment jurisdiction.

XLII. Practical Guidance for Litigants

A person involved in an impeachment-related controversy should identify the true issue before choosing a remedy.

If the goal is to accuse an impeachable officer, use the impeachment process in the House.

If the goal is to challenge unconstitutional impeachment procedure, consider a proper petition before the Supreme Court.

If the goal is to prosecute a crime, proceed through the proper prosecutorial office and court.

If the goal is to recover damages for a private wrong, file in the proper civil court, but avoid asking the court to control impeachment.

If the goal is to discipline a non-impeachable public officer, use the appropriate administrative remedy.

Filing in an RTC to control impeachment is generally improper.

XLIII. Conclusion

Regional Trial Courts do not have jurisdiction over impeachment proceedings in the Philippines. They cannot initiate impeachment, stop the House from processing impeachment complaints, restrain the Senate from conducting an impeachment trial, review congressional impeachment acts, or decide whether an impeachable officer should be removed.

Impeachment belongs constitutionally to Congress: initiation to the House of Representatives and trial and decision to the Senate. Judicial review may exist only in limited circumstances, generally through the Supreme Court, where there is a genuine constitutional issue or grave abuse of discretion.

The proper legal understanding is that impeachment is neither lawless nor subject to ordinary trial court control. It is a constitutional process with its own assigned institutions, remedies, and limits. RTC intervention is generally barred because it would violate the constitutional design, separation of powers, and the exclusive and sole impeachment powers granted to Congress.