The present Petition for Mandamus^[1] seeks to compel the Senate of the Philippines (Senate) to constitute itself into an impeachment court and conduct the trial of Vice President Sara Z. Duterte (VP Duterte) without further delay.

Antecedents

Petitioner Catalino Aldea Generillo, Jr. (Generillo, Jr.) claims standing to file the present case as a member of the legal profession who has handled high-profile cases involving public interest.^[2] On the other hand, respondent Senate of the Philippines (Senate) is represented by its Senate President Francis G. Escudero (Senate President Escudero).^[3]

Relying on news reports found online,^[4] Generillo, Jr. narrates that Speaker Ferdinand Martin Romualdez (Speaker Romualdez) of the House of Representatives (House) directed House Secretary General Reginald S. Velasco (House Secretary General Velasco) to transmit to the Senate the impeachment complaint filed by 215 representatives, or more than one-third of its members, against VP Duterte on February 5, 2025.^[5] Senate Secretary Renato Bantug (Senate Secretary Bantug) received the Articles of Impeachment on the same day.

The following day, or on February 6, 2025, Senate President Escudero announced that the Senate will not hold the impeachment trial during its session break because the Senate can only be convened as an impeachment court in a plenary session.^[6] In a press briefing held on February 10, 2025, Senate President Escudero made another announcement, declaring that the offices of all the senators received their respective copies of the impeachment complaint and its annexes. Digital copies are also uploaded to the Senate website for public access.^[7]

Generillo, Jr. contends that the Constitution does not allow the Senate to procrastinate during the period it is on recess. To support this contention, he quotes the provisions of the Constitution pertinent to the impeachment process:

ARTICLE XI
ACCOUNTABILITY OF PUBLIC OFFICERS Section 3.

1.	The House of Representatives shall have the exclusive power to initiate all cases of impeachment.
2.	A verified complaint for impeachment may be filed by any Member of the House of Representatives or by any citizen upon a resolution or endorsement by any Member thereof, which shall be included in the Order of Business within ten session days, and referred to the proper Committee within three session days thereafter. The Committee, after hearing, and by a majority vote of all its Members, shall submit its report to the House within sixty session days from such referral, together with the corresponding resolution. The resolution shall be calendared for consideration by the House within ten session days from receipt thereof.
3.	A vote of at least one-third of all the Members of the House shall be necessary either to affirm a favorable resolution with the Articles of Impeachment of the Committee, or override its contrary resolution. The vote of each Member shall be recorded.
4.	In case the verified complaint or resolution of impeachment is filed by at least one-third of all the Members of the House, the same shall constitute the Articles of Impeachment, and trial by the Senate shall forthwith proceed. (Emphasis in the original)

Insisting that words must be used in their ordinary meaning, Generillo, Jr. refers to the Oxford Dictionary to assert that "forthwith" should be taken to mean "immediately," "at once," "instantly," "directly," "right away," "straight away," "now," "instantaneously," "without delay," "without hesitation," "unhesitatingly," "quickly," "speedily," "with all speed," "promptly," "expeditiously," "pronto."^[8] Generillo, Jr. further asserts that the members of the Senate are not suffering from any kind of disability that prevents them from constituting themselves into an impeachment court and conduct public trial.

In a Resolution^[9] dated February 18, 2025, this Court directed the Senate to file its Comment. The Senate, through the Office of the Solicitor General, filed a Motion for Extension to file Comment dated May 6, 2025.^[10] It sought a 15-day extension from May 9, 2025, or until May 24, 2025. Generillo, Jr. filed an Opposition to the Motion for Extension of Time to File Comment dated May 9, 2025.^[11] We granted the Senate's Motion for Extension in a Resolution dated May 20, 2025.^[12] The Senate filed its Comment dated May 19, 2025^[13] on May 26, 2025.

In its narration of factual antecedents, the Senate does not contradict Generillo, Jr.'s allegations and adds details from its perspective, thus:

2. On February 5, 2025, [Speaker Romualdez] directed [House Secretary General Velasco] to immediately transmit to the Senate the impeachment complaint against [VP Duterte]. The complaint, filed by 215 out of 306 House members, exceeded the one-third threshold required under the 1987 Constitution.

3. At approximately 4:47 p.m. on the same day, [House Secretary General Velasco] personally delivered the impeachment complaint and its supporting documents to [Senate Secretary Bantug] at the Senate. The transmittal occurred just hours before Congress adjourned for its scheduled recess from February 6 to June 1, 2025, with sessions set to resume on June 2, 2025 until the sine die adjournment on June 13, 2025.

4. On February 6, 2025, [Senate President Escudero] issued a public statement clarifying that the Senate would not convene as an impeachment court during the congressional recess. He stated that the Senate would use the recess period to review and update its impeachment rules. On the same date, Senate Secretary Bantug commenced complete staff work procedures to check the signatures affixed on the transmitted impeachment complaint, in preparation for distributing copies thereof to the individual senators. The Senate Legal Counsel also submitted the initial draft of proposed amendments to the Rules of Procedure on Impeachment Trials to Senate Secretary Bantug for review.

5. On February 10, Senate Secretary Bantug completed the checking of the signatures contained in the impeachment complaint and reported to Senate President Escudero that per visual inspection, it contained the wet ink signatures of 215 members of the House of Representatives. On the same date, Senate President Escudero announced that copies of the impeachment complaint had been distributed to all 23 senators and that its full text, along with annexes, had been uploaded to the Senate website for public access. The Senate had also proceeded to make other preparations, such as reviewing the expense items and actual expenses incurred in previous impeachment trials based on available records.

6. In the meantime, [Generillo, Jr.] filed the instant Petition for Mandamus dated February 13, 2025, arguing that the Senate has a ministerial and "inescapable constitutional duty" to convene into an impeachment court and commence the trial proper.

7. From February 18-19, 2025, various support services submitted their respective inputs in preparation for the impeachment proceedings. The Senate Legal Counsel also submitted proposed amendments to the Rules of Procedure on Impeachment Trials.

8. In a press conference held on February 19, 2025, Senate President Escudero provided updates on the Senate's preparation for the impeachment trial, including doing a mock set up for the impeachment court and witness stands, the arrangement of the ID system for guests and members of the prosecution and defense, and the procurement of robes.

9. On February 20, 2025, Senate President Escudero signed Special Order No. 2025-0915 (OSP), establishing an administrative support group that will assist the Senate throughout the impeachment trial. SP No. 2025-015 designated both the impeachment court's clerk of court and support offices, outlined their respective functions, and authorized the Secretary of the Senate to issue administrative orders, directives, and guidelines as may be necessary to implement it.

10. On February 27, 2025 Senate President Escudero submitted to the Senate the proposed calendar for [VP Duterte's] impeachment trial. In accordance with the schedule, the trial and its preparations would proceed as follows:

June 2	Resumption of session and presentation of articles of impeachment.
June 3	Convening of impeachment court and oathtaking of incumbent senator-judges
June 4	Issuance of summons
June 14-24	Reception of pleadings
June 24 - July 25	Pre-trial
July 29	Oathtaking of newly-elected senator judges before sitting as an impeachment court.
July 30	Start of trial

11. On March 19, 2025, the Senate received Secretary General Velasco and other House officials for purposes of inspecting the facilities to be used in the impeachment trial, such as the session hall and the rooms allotted for the prosecution team. Throughout March, the Senators also proceeded to take measurements and procure their ceremonial robes for purposes of the trial.

12. Currently, members of the Senate Legal Counsel are still finalizing the proposed amendments to the Rules of Procedure on Impeachment Trials.^[14]

In its Comment, the Senate argues that the Petition must be dismissed for being moot, considering that it has already commenced preparations for the impeachment trial. The Senate's duty and power to try impeachment cases involves not only the conduct of the trial but also all the preparations needed for the orderly conduct of the trial. These include the promulgation of impeachment rules and arrangements for finance, logistics, and security aspects of the trial.^[15]

The Senate also asserts that Generillo, Jr. has no legal standing for failing to show a specific legal right to which he is entitled. There is no demonstration that Generillo, Jr. is directly injured by the Senate's act or omission. Generillo, Jr.'s mere invocation of transcendental importance does not relax the requirement of locus standi. Although it may be claimed that Generillo, Jr. is vindicating a public right, the remedy of mandamus is only available if Generillo, Jr. can show a specific legal right personally denied to him.^[16]

Assuming arguendo that Generillo, Jr. has legal standing, the Senate submits that the petition should still be dismissed because mandamus is an improper remedy. The Senate's duty to try and decide cases is not ministerial. The writ of mandamus can only compel the performance of a ministerial duty which does not require the exercise of official discretion or judgment. While the Constitution assigned to the Senate the duty to try and decide impeachment cases, it did not impose a strict timeframe. Such deliberate omission indicates that the framers left such determination to the Senate's sound judgment and its own procedural rules. Thus, the manner of conducting the impeachment trial, the preparations needed, and the timeframe are within the Senate's sound discretion. The Senate's discretion on this matter is a political question which the Court cannot review.^[17]

Finally, the Senate declares that the term "forthwith" does not mean the Senate must proceed immediately to the impeachment trial without making the necessary preparations. It makes a distinction between the two modes of initiating an impeachment complaint, that is, one filed by individual citizens or legislators and the other through a verified complaint or resolution filed by at least one-third of the members of the House. The term "forthwith" means that, in the second mode, filing of the complaint before the Senate is the immediately succeeding step when an impeachment complaint is initiated by one-third of the members of the House of Representatives. Any interpretation of immediacy must also give due regard to the reasonableness of preparing for trial and the complexities and nuances of each impeachment case.^[18]

Generillo, Jr. filed a Reply^[19] dated June 5, 2025. He insists that the Senate's Comment be stricken off the record as this Court has not resolved its Motion for Extension to file Comment. He also prays that this Court issue an order directing to the Senate to convene as an impeachment court and to proceed with the trial of VP Duterte immediately.^[20]

Issue

We note that petitioner only raised a single issue in his Petition: whether the Senate, after it received the impeachment complaint filed by the House against VP Duterte, has the inescapable constitutional duty to convene immediately as an impeachment court and forthwith conduct public trial.^[21]

Ruling of the Court

We dismiss the petition.

Petitioner filed a petition for mandamus to ask this Court to issue an order directing the Senate to immediately convene as an impeachment court to conduct the public trial of VP Duterte.

The grounds for filing a petition for mandamus are governed by Rule 65, Section 3 of the Rules of Court, which provides:

Section 3. Petition for mandamus. - When any tribunal, corporation, board, officer or person unlawfully neglects the performance of an act which the law specifically enjoins as a duty resulting from an office, trust, or station, or unlawfully excludes another from the use and enjoyment of a right or office to which such other is entitled, and there is no other plain, speedy and adequate remedy in the ordinary course of law, the person aggrieved thereby may file a verified petition in the proper court, alleging the facts with certainty and praying that judgment be rendered commanding the respondent, immediately or at some other time to be specified by the court, to do the act required to be done to protect the rights of the petitioner, and to pay the damages sustained by the petitioner by reason of the wrongful acts of the respondent.

There are two types of mandamus. In mandamus to enforce a clear legal duty, the focal point is on "an act which the law specifically enjoins as a duty resulting from an office, trust, or station," whereas in mandamus against unlawful exclusion, the focus is on "a right or office" to which the petitioner is entitled. In the former, the actionable wrong is the respondent's unlawful neglect to perform a duty, while in the latter, it is the respondent's unlawful exclusion of petitioner. Mandamus in the first sense rectifies unlawful inaction, and in the second, unlawful action.^[22]

The Senate is part of a coordinate and independent branch of the government. Its action within its sphere cannot be revised or controlled by mandamus by the judicial department, without a gross usurpation of power upon the part of the latter.^[23] Petitioner failed to convince this Court that mandamus would lie to compel the Senate to act within an expected timeframe upon its receipt of the impeachment complaint. As a co-equal constitutional body, the Senate exercises its duties which are beyond this Court's power of review, save for clearly established circumstances showing grave abuse of discretion or whimsical and despotic exercise of power. Thus, mandamus is an inappropriate remedy for the issue raised in this case. This view is shared by Associate Justice Maria Filomena D. Singh in her separate opinion.

The foregoing disquisition notwithstanding, this Court treats the present petition as one for certiorari, pro hac vice, in the interest of equity. This is in line with the time-honored principle that rules of procedure should promote, not defeat, substantial justice. For the present case, We opt to apply the Rules liberally to resolve the substantial issues raised by the parties.^[24]

In doing so, We address the cardinal issue of defining "forthwith" as used in Article IX, Section 3(4) of the Constitution. Corollary to this, We resolve whether the Senate committed unlawful inaction when it did not tackle the impeachment complaint upon receipt. In other words, this Court shall resolve whether the Senate committed grave abuse of discretion in not convening itself as an impeachment court after it had received the impeachment complaint.

In Integrated Bar of the Philippines v. Zamora,^[25] We stated that, 'legal standing' or locus standi has been defined as a personal and substantial interest in the case such that the party has sustained or will sustain direct injury as a result of the governmental act that is being challenged. The gist of the question of standing is whether a party alleges such personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues upon which the court depends for illumination of difficult constitutional questions.

Consistent with jurisprudence, this Court has adopted a liberal stance on locus standi where a petitioner raises issues of transcendental importance to the Filipino people, particularly when paramount constitutional or public interests are at stake. When the matter transcends individual concerns and touches upon overarching public interests demanding urgent resolution, rigid procedural rules yield to substantive justice.^[26]

The impeachment of the Vice President-the Republic's second highest official-epitomizes such transcendental public concern, as it presents issues affecting the fabric of constitutional governance under Article XI, Section 3 of the 1987 Constitution, thereby conferring upon petitioner the requisite legal standing to seek redress before this Court.

Furthermore, Our observation in GIOS-Samar v. Department of Transportation and Communications,^[27] that when the transcendental importance of the constitutional issue raised is used to excuse a violation of the principle of the hierarchy of courts, resolution of factual matters is not necessary for the resolution of the constitutional issues, applies here. The Senate did not dispute petitioner's narration and even added details to corroborate it to demonstrate their preparations. Petitioner, on the other hand, has no quarrel with the details supplied by the Senate.

In Nixon v. U.S.,^[28] the Supreme Court of the United States (SCOTUS) explained that a controversy is nonjusticiable where there is a "textually demonstrable commitment of the issue to a coordinate political department; or a lack of judicially discoverable and manageable standards for resolving it." Thus, the SCOTUS held in Nixon that there could be no judicial intervention in impeachment proceedings, which involve political questions or nonjusticiable issues. It found that there are no judicially discoverable and manageable standards for resolving questions involving the Senate of the United States' exercise of its sole power to try impeachment cases. This strengthens the SCOTUS' holding that there is a textually demonstrable commitment of issues involving impeachment to the Senate.

However, this Court clarified in Francisco, Jr. v. House of Representatives^[29] that the holding in Nixon cannot apply in the Philippines because the 1987 Constitution contains several provisions dictating how the House must exercise its exclusive power to file impeachment complaints before the Senate.

Similarly, the constitutional issue raised here is justiciable considering that it asks the Court to determine whether the Senate's acts or omissions have breached the limits and standards imposed by the Constitution on its power to try and decide impeachment cases.

A.	"Forthwith" considers the circumstances of each particular case

The term "forthwith" is defined in the Black's Law Dictionary as: (a) immediately; without delay; (b) directly; promptly; (c) within a reasonable time under the circumstances; and (d) with all convenient dispatch.^[30]

The Records of the 1986 Constitutional Commission reveal no substantive debate on the term "forthwith" in Article XI, Section 3(5). However, former Supreme Court Justice Adolf Azcuna, a member of the 1986 Constitutional Convention that drafted Article XI of the 1987 Constitution, took to social media and stated that he included the word "forthwith" referring to the need for the Senate to proceed with the trial after the House adopts a Resolution of Impeachment. According to Justice Azcuna: "It is precisely meant to mean immediately and without reasonable delay or in the National language official version 'agad-agad."'^[31]

In Philippine jurisprudence, the word "forthwith" was held by the Court in Fischer v. Ambler^[32] to mean within a reasonable time, which may be a longer or shorter period, according to the circumstances of each particular case. In that case, the Court interpreted the term "forthwith" as used in Section 142 of the Code of Procedure, which provides that "the party excepting to the ruling, order, or judgment shall forthwith inform the court that he excepts to the ruling, order, or judgment."

In the subsequent case of Behn, Meyer & Co. v. Antholtz,^[33] the Court once again expounded on the meaning of the term "forthwith" as used in Section 142 of the Code of Procedure, thus:

The Code of Civil Procedure provides in its section 142 that "the party excepting to the ruling, order, or judgment shall forthwith inform the court that he excepts to the ruling, order or judgment, ... " On the doubtful assumption that this portion of the code is applicable, then it remains to be said that the expression "forthwith" is one which cannot be scientifically circumscribed. The term is elastic in nature. It is a relative one. Its meaning varies with every case.

In this jurisdiction, "forthwith" has been held to mean within a reasonable time, which varies according to the circumstances (Fischer vs. Amber [1902], 1 Phil. 508). In the cited case, this court avoided a definitive ruling of whether a delay of thirteen days was unreasonable, this question being left for determination, if necessary, upon a motion to dismiss. (Emphasis supplied)

Parenthetically, the word "forthwith" has been defined in jurisprudence of the United States (US) as: (a) without unnecessary delay and requires reasonable exertion and due diligence consistent with all the facts and circumstances of the case;^[34] (b) without delay, at once, promptly;^[35] ( c) as soon as practicable;^[36] ( d) without unnecessary delay and required reasonable exertion;^[37] (e) immediately, without delay, or promptly;^[38] and (f) immediately.^[39]

A perusal of the two Philippine cases interpreting the term "forthwith" reveals that in our jurisprudence, "forthwith" means within a reasonable time, which may be a longer or shorter period, according to the circumstances of each particular case. That is, the term is elastic in nature and its meaning varies in every case. Even in US jurisprudence, with its varied definitions attributed to the term "forthwith," the courts did not just consider the lapse of time in ruling whether there is a violation of the "forthwith" provision. The courts therein invariably evaluated the facts and circumstances of each case to determine whether there is due diligence to carry out the legislative intent of the "forthwith" provision involved.

B.	Trial by the Senate includes acts done in preparation for the trial

Petitioner insists that the Senate constitute itself into an impeachment court and forthwith conduct public trial of VP Duterte. This insistence disregards any prior preparation on the part of the Senate for the conduct of an impeachment trial. On the other hand, the Senate submits that its duty "encompasses the promulgation or amendment of [impeachment] rules, as well as the preparation necessary in accordance with the same. These necessarily include the implied and incidental duties to undertake all preparations necessary [sic] to ensure the orderly functioning of the impeachment court. These cover responsibilities relating to, among other things, finance, logistics and security."^[40]

Due to the parties' contrasting views, there is a difference in their explanation about the preparations needed for the conduct of an impeachment trial. Petitioner neither mentions nor argues about the inclusion of preparations in the conduct of the trial. In contrast, the Senate painstakingly specified the amount of work needed prior to the conduct of an impeachment trial: (1) on February 6, 2025, the Senate reexamined the amendments to the rules of procedure on impeachment trial;^[41] (2) on February 10, 2025, the Senate's Deputy Secretary for Administrative and Financial Services asked Senate Secretary Bantug to review the budgetary requirement for the impeachment trial;^[42] (3) on February 18, 2025, the Senate's Service Chief for Management Information Systems manifested its readiness to demonstrate a QR-based online visitor registration system;^[43] (4) on February 18, 2025, the Senate's Bureau Director for Maintenance and General Services submitted documentation for ingress traffic flow on the relevant floor of the Senate building, as well as the furniture layouts and seat capacities for the rooms to be used in relation to the impeachment trial;^[44] (5) from February 11 to 20, 2025, Senate personnel prepared design studies of the personnel identification card, the access tickets, and the impeachment court seal;^[45] and (6) on February 20, 2025, Senate President Escudero issued OSP No. 2025-015 on the organization of administrative support to the Senate sitting as an Impeachment Court.^[46]

To these, We add that the 2025 National and Local Elections were conducted on May 12, 2025, and canvassing results and proclamation of winners for members of Congress and the local governments were carried out from May 13 to May 19, 2025.^[47] The third regular session of the 19^th Congress of the Philippines went on sine die adjournment on June 11, 2025.^[48]

C.	The Petition is already moot

We agree with the Senate's position. The acts done in preparation for the impeachment trial, as well as the nullification of the Articles of Impeachment, have rendered the petition moot. This view is shared by Associate Justices Jhosep Y. Lopez and Maria Filomena D. Singh in their respective separate opinions. On the other hand, Associate Justice Henri Jean Paul B. Inting agrees with the mootness argument from a different perspective, i.e., the expiration of the term of the 19^th Congress on June 20, 2025.^[49]

We affirmed in Duterte v. House of Representatives^[50] that the Senate is a continuing body, unlike the House of Representatives which expires as a body upon the termination of the term of Congress.^[51]

In Arnault v. Nazareno,^[52] We first recognized the Senate as a continuing body, albeit specifically in relation to the exercise of its contempt powers. We held that the Senate has no time limit in exercising its power to punish contemptuous acts since it does not expire on the final adjournment of its last session. We reiterated this holding in Neri v. Senate Committee on Accountability of Public Officers and Investigations^[53] but clarified:

On the nature of the Senate as a "continuing body", this Court sees fit to issue a clarification. Certainly, there is no debate that the Senate as an institution is "continuing," as it is not dissolved as an entity with each national election or change in the composition of its members. However, in the conduct of its day-to-day business the Senate of each Congress acts separately and independently of the Senate of the Congress before it.^[54]

We also affirmed Arnault's holding in Balag v. Senate of the Philippines^[55] but maintained Neri's dichotomy of the Senate's continuity as an institution and the conduct of its unfinished day-to-day business:

Based on the above-pronouncement, the Senate is a continuing institution. However, in the conduct of its day-to-day business, the Senate of each Congress acts separately and independently of the Senate of the Congress before it. Due to the termination of the business of the Senate during the expiration of one (1) Congress, all pending matters and proceedings, such as unpassed bills and even legislative investigations, of the Senate are considered terminated upon the expiration of that Congress and it is merely optional on the Senate of the succeeding Congress to take up such unfinished matters, not in the same status, but as if presented for the first time.

The termination of the Senate's business and proceedings after the expiration of Congress was utilized by the Court in ruling that the Senate needs to publish its rules for its legislative inquiries in each Congress. The pronouncement in Neri was reiterated in Garcillano v. House of Representatives and Romero II v. Estrada.^[56] (Emphasis in the original)

All told, jurisprudence has consistently characterized the Senate as a continuing body that does not dissolve as an institution upon every national election or change in its membership. However, in the context of the Senate's legislative matters (e.g., unpassed bills) and proceedings in relation to its legislative power (e.g., legislative inquiries and contempt citations in those inquiries), all of these do not carry over to the next Congress.

Nevertheless, this case has already been rendered moot by Our July 25, 2025 Decision and January 28, 2026 Resolution in Duterte which nullified the Articles of Impeachment against VP Duterte.

A case is moot and academic when it "ceases to present a justiciable controversy by virtue of supervening events, so that a declaration thereon would be of no practical use or value."^[57]

Since there is currently no valid Articles of Impeachment pending against VP Duterte, there is obviously no basis for the Court to order the Senate to convene as an impeachment court. Under Article XI, Section 3(4) of the 1987 Constitution, it is the filing of the verified impeachment complaint or resolution by at least one-third of all members of the Houses of Representatives that triggers the Senate's duty to "forthwith proceed" with the trial.

But even before Our rulings in Duterte, the Petition would still have been dismissed on the ground of mootness.

In Pagdanganan v. Court of Appeals,^[58] a petition for mandamus was filed before this Court to compel the Court of Appeals to resolve a pending petition for certiorari, prohibition and mandamus. Before this Court could resolve the petition for mandamus, the Court of Appeals rendered a decision and resolution resolving the petition for certiorari, prohibition, and mandamus. Thus, this Court dismissed the petition for mandamus for being moot because "[a]ny issuance of a writ of mandamus...becomes an exercise in futility [since] [t]he Court of Appeals cannot be compelled to resolve a case it has already fully resolved."^[59]

Similarly, issuing a writ of mandamus in this case would serve no practical purpose, as the Senate complied with its constitutional duty to try and decide impeachment cases, as discussed above. This Court refuses to create a legal absurdity and compel the Senate to perform an act that it has already done.

Even on the merits, however, the petition should still be dismissed.

To put things in perspective, We compare the preparations done by the Senate with the events in the previous impeachment trials. Despite numerous complaints filed against various officials who are subject to impeachment, only two officials underwent an impeachment trial.

1.	The impeachment trial of President Joseph Estrada

On October 5, 2000, Senate Minority Leader Teofisto Guingona, Jr. delivered a privilege speech entitled, "I Accuse," on President Joseph Ejercito Estrada's (President Estrada) alleged receipt of approximately PHP 220 million in jueteng money and PHP 70 million on excise tax on cigarettes intended for Ilocos Sur from Ilocos Sur Governor Luis Singson (Governor Singson).^[60] Senate President Franklin Drilon (Senate President Drilon) referred the matter to the Senate Blue Ribbon Committee and the Committee on Justice for joint investigation.

During the House's session on November 13, 2000, Speaker Manuel Villar (Speaker Villar) declared that 115 representatives, or more than one-third of the Members of the House, signed the Articles of Impeachment against President Estrada.^[61] He ordered to transmit the Articles of Impeachment to the Senate. Thereafter, changes were made in the leadership of both the Senate and the House.^[62]

A week after the referral of the Articles of Impeachment, or on November 20, 2000, the Senate convened itself into an Impeachment Court.^[63]

On November 28, 2000, the Impeachment Court dismissed the motion to quash filed by the defense.^[64] Then, it adjourned its session until December 7, 2000.^[65] Trial proceeded from day to day. Adjournments were made in consideration of weekends and holidays.

On December 22, the last day of the hearings before the Impeachment Court adjourned for the holidays, Clarissa Ocampo (Ocampo), senior vice president of Equitable-PCI Bank, testified that she was one foot away from President Estrada when he affixed the signature "Jose Velarde" on documents involving a multi-million peso investment agreement with their bank.^[66] The Impeachment Court adjourned soon after her testimony.^[67]

The trial proceeded during the weeks of January 2, 8, and 15, 2001.^[68] On January 16, 2001, the senator-judges voted 11-10 and ruled against opening an envelope that allegedly contained evidence that President Estrada held more than PHP 3 billion in a secret bank account under the name "Jose Velarde." This event prompted the members of the prosecution to walk out of the Impeachment Court, and sparked the beginning of rallies at the EDSA Shrine.^[69]

The military and the police withdrew their support from the Estrada Administration.^[70] Some. Cabinet secretaries and their subordinates resigned from their posts.^[71] The transition of power happened on January 20, 2001, with Vice President Gloria Macapagal-Arroyo taking her oath as President at noon.^[72] At around 2:30 p.m. of the same day, President Estrada left Malaca ang.^[73]

On February 7, 2001, the Senate passed Senate Resolution No. 83 declaring that the impeachment court is functus officio and has been terminated.^[74]

Despite the Senate being in session, President Estrada's impeachment trial did not start until three weeks after the Articles of Impeachment were filed. The Senate also went on recess and took a Christmas break during the trial. The impeachment trial ended with the issuance of a Senate resolution announcing the outcome.

2.	The impeachment trial of Chief Justice Renato Corona

Unlike the abrupt ending of President Estrada's trial, the impeachment trial of Chief Justice Renato Corona (Chief Justice Corona) ended with a verdict.

On December 12, 2011, the majority bloc of the House held a caucus and submitted a verified impeachment complaint against Chief Justice Corona to the House Committee on Justice.^[75] On the same day, House members voted in session, and 188 House members signed and endorsed the complaint.^[76]

The Senate received the verified complaint, which constituted the Articles of Impeachment against Chief Justice Corona, on December 13, 2011.^[77] At 4:10 p.m. on the next day, Senate President Juan Ponce Enrile (Senate President Enrile) constituted and convened the Senate as an Impeachment Court.^[78] He took his oath as Presiding Officer, and the Members of the Senate took their oaths as Judges.^[79] Thereafter, the impeachment trial was adjourned until 2:00 p.m. of January 16, 2012.^[80]

On December 15, 2011, Chief Justice Corona received a copy of the complaint.^[81] He filed his Answer on December 26, 2011.^[82] Both the prosecution and defense teams made public disclosures even before the trial commenced.^[83]

More than a month after its receipt of the Articles of Impeachment, or on January 16, 2012, the Senate, acting as an Impeachment Court, commenced trial proceedings against Chief Justice Corona.^[84] He pleaded not guilty to the charges enumerated in the Articles of Impeachment.^[85]

From January 18 to February 28, 2012, the prosecution presented its witnesses and evidence on Chief Justice Corona's alleged ill-gotten wealth. Meanwhile, on February 9, 2012, this Court issued a Temporary Restraining Order enjoining the Senate sitting as an Impeachment Court from compelling the disclosure of Chief Justice Corona's foreign currency accounts.^[86] In complying with the order, the Impeachment Court, through its Presiding Officer, Senate President Enrile, declared that the Court cannot assume jurisdiction over the Senate to try and decide an impeachment case on the merits.^[87] When the prosecution ended its presentation of evidence and witnesses, it also withdrew the presentation of Articles 1, 4, 5, 6, and 8 of the Articles of Impeachment.^[88]

Chief Justice Corona's defense team conducted its cross-examination in the succeeding trial dates. The defense presented its case from March 12 until May 25, 2012.^[89] Adjournments were made on March 15 and 22, and May 8, 16, 23, and 25. Corresponding resumptions of session ensued on March 19, and May 7, 14, 22, 25, and 28.

It should be noted that when the Impeachment Court went on recess upon the adjournment of the Senate session on March 22, 2012,^[90] proceedings resumed on May 7 and 8, 2012, or approximately six weeks from the last trial date.^[91]

On May 22, 2012, Chief Justice Corona delivered a statement and left the session hall soon after.^[92] The impeachment proceedings resumed the next day, with the Impeachment Court granting the defense until May 25, 2012 to finish their evidence.^[93] On even date, the defense submitted its formal offer of evidence and rested its case.^[94] The Impeachment Court again adjourned until May 28, 2012, when both the prosecution and the defense delivered their closing statements."^[95]

Finally, on May 29, 2012, the Impeachment Court voted 20-3 against Chief Justice Corona.^[96] With the conclusion of the impeachment trial, the case was terminated, and the Senate, acting as an Impeachment Court, adjourned sine die.^[97]

Notably, the Senate received the Articles of Impeachment from the House of Representatives while it was in session. After constituting itself as an Impeachment Court, the Senate proceeded to trial more than a month from its receipt of the Articles of Impeachment. The trial survived multiple adjournments and lasted for 44 days.^[98]

3.	The Court's Decision in Duterte v. House of Representatives and the action of the Senate in the 20th Congress

We partially granted the petitions in Duterte.^[99] The House effectively dismissed the first three impeachment complaints against VP Duterte, which were filed pursuant to Article XI, Section 3(2) of the Constitution, when they remained unacted upon and archived by the 19^th Congress prior to its adjournment.

The fourth impeachment complaint, which was filed in accordance with Article XI, Section 3(4) and subsequently transmitted to the Senate, is barred by the one-year rule under Article XI, Section 3(5) of the Constitution. Its filing was considered a separate and distinct mode of initiating the impeachment process. The Articles of Impeachment against VP Duterte were then declared unconstitutional, and deemed null and void ab initio.

Consequently, We held that the Senate did not acquire jurisdiction to constitute itself into an impeachment court. On this score, We find it necessary to emphasize that, under the given circumstances as applied, it is impossible for the Senate to commit grave abuse of discretion, as Senior Associate Justice Marvic M.V.F. Leonen would prefer to have this Court rule.

On August 6, 2025, the senators of the 20^th Congress discussed the effects of Our July 25, 2025 Decision in Duterte on their jurisdiction as an impeachment court. Without constituting itself as an impeachment court, the Senate voted to transfer to the Archives the Articles of Impeachment in relation to Case No. 003-2025, entitled In the Matter of the Impeachment Trial of Vice President Zimmerman Duterte.^[100]

In Our Resolution dated January 28, 2026, We partially granted the Motion for Reconsideration and recognized the fact of transmittal of the Articles of Impeachment by the House of Representatives to the Senate on February 5, 2025.^[101]

4.	Comparison of the impeachment proceedings against President Estrada and Chief Justice Corona with that against VP Duterte

The timeline of preparations for the impeachment trials of President Estrada and Chief Justice Corona did not face the same scrutiny as that of VP Duterte. The relevant events and dates, including adjournments and resumptions, in the three impeachment trials are compiled in the table below. The table also shows the number of calendar days between events.

During President Estrada's trial, the constitution of the Senate as an Impeachment Court took seven days from its receipt of the Articles of Impeachment, while it took 33 days during Chief Justice Corona's trial. The Senate of the 19^th Congress, on the other hand, took 126 days before it convened itself into an Impeachment Court. The processes in the Senate took 64, 168, and 182 days for President Estrada, Chief Justice Corona, and VP Duterte, respectively.

Notably, Congress was in session when the House transmitted and the Senate received the Articles of Impeachment against President Estrada and Chief Justice Corona. In the case of VP Duterte, the House transmitted the Articles of impeachment after office hours on the last session day.

The Senate has the solemn constitutional duty to try and decide impeachment cases. Article XI, Section 3(4) of the Constitution could not be any clearer when it says that "trial by the Senate shall forthwith proceed" once the verified complaint or resolution of impeachment-constituting the Articles of Impeachment-is filed by at least one-third of all the members of the House of Representatives. The Constitution did not distinguish between the Senate and the Impeachment Court.

Indeed, the text of the Constitution is neutral about the Senate's character and merely refers to it as the Senate. There is no mandatory language that the Senate transform itself into an Impeachment Court before it can do any act that may be construed as related to impeachment.

Similarly, the Senate's Rules of Procedure in Impeachment Trials do not expressly speak of the need to convene the Senate into an Impeachment Court before it may perform any act related to the impeachment process. The receipt of the Articles of Impeachment is made by the Senate.^[109] The oathtaking of the Chief Justice as Presiding Officer is made by the Senate President^[110] and precedes the oathtaking of the Members of the Senate^[111] as Members of the Impeachment Court. The constitution of the Senate as an Impeachment Court becomes relevant only for the consideration of the Articles of Impeachment.

The verba legis rule must be observed in constitutional interpretation. That is, the words in the Constitution must be given their ordinary meaning except where technical terms are employed.^[112] The word "shall" connotes a mandatory order or an imperative obligation-pointing to a command that must be given a compulsory meaning.^[113] Thus, the use of the modal verb "shall" in Article XI, Section 3(4) signifies a command to the Senate to "forthwith proceed" with the "trial" once the verified complaint or resolution of impeachment is filed by at least one-third of all the members of the House of Representatives.

The filing of the verified complaint or resolution of impeachment by the House of Representatives triggers the Senate's constitutional obligation to "forthwith proceed" with the "trial." In the present case, the Senate's obligation under Article XI, Section 3(4) was triggered when House Secretary Velasco transmitted the impeachment complaint against VP Duterte to the Senate, through Senate Secretary Bantug, on February 5, 2025.

The crucial issue now is whether the Senate gravely abused its discretion by not immediately convening as an impeachment court and conducting the impeachment trial.

Senior Associate Justice Leonen takes the position that the immediacy in "forthwith" is demanded, not in the completion of a complex trial, but in the convening of the impeachment court and the commencement of the constitutional process. He opines:

The Senate President's immediate duty, upon receipt of the Articles of Impeachment, was to place the matter before the Senate for the purpose of constituting the impeachment court. It was the impeachment court, not the Senate as a legislative body, that should have supervised the preparations for the trial and determined the schedule of proceedings. The legislative recess, as an agreement between legislative bodies about the suspension of legislative work, had no force against the mandatory command addressed to a constitutional tribunal.^[114]

The Court does not decide in a vacuum. It considers the confluence of factual circumstances of the cases before it. The totality of circumstances in the present case do not support a finding of grave abuse of discretion by the Senate:

1. The House transmitted the Articles of Impeachment after office hours on the last session day.
2. The petition was filed only eight days after transmittal.
3. This Court declared the same Articles of Impeachment void.
4. There can be no valid Special Session concerning void Articles of Impeachment.
5. All these happened before the promulgation of this Court's Decision in the present petition.

Grave abuse of discretion is committed "when an act is (1) done contrary to the Constitution, the law or jurisprudence or (2) executed whimsically, capriciously or arbitrarily, out of malice, ill will or personal bias."^[115] Neither are present here.

As discussed, the Senate's obligation under Article XI, Section 3(4) includes not only the conduct of the actual trial itself but also preparatory acts for the trial. We note that the Senate has already started its preparations for conducting the impeachment trial. Petitioner did not dispute this fact.

Article XI, Section 3(4) does not provide any specific period when the Senate must conduct the impeachment trial, unlike Section 3(2), where the House of Representatives is commanded to perform and accomplish certain acts within a specified period:

1. Once a verified complaint for impeachment is filed, the House must include it in its "Order of Business within [10] session days,"
   
   
2. The House must then refer the verified complaint for impeachment to the "proper Committee within three session days thereafter,"
   
   
3. The proper Committee must submit its report and its corresponding resolution to the House "within [60] session days from such referral," and
   
   
4. The House must calendar the resolution for consideration "within [10] session days from receipt thereof."

The Constitution clearly intended the House of Representatives to act on an impeachment complaint within a given period. It expressly provided the number of session days when a specific act must be done or accomplished. The same cannot be said about the Senate's obligation to conduct the impeachment trial.

Article XI, Section 3(4) simply says that the impeachment trial "shall forthwith proceed." There is no textual commitment to a specific number of days for the Senate to begin the actual trial. This obvious omission indicates that it is for the Senate to determine when it will conduct the actual trial, considering the preparations it deems necessary to convene as an impeachment court and discharge its duty as such.

While We reiterate that no hard and fast rule mandates an explicit number of days for a specific Senate response, We acknowledge the difference in the speed by which the Senate of the 19^th Congress acted with regard to preparations for impeachment and in not constituting itself as an impeachment court. With due regard, however, to the totality of circumstances involved, We find that the preparations for VP Duterte's impeachment trial were done within a reasonable period.

The Petition fails to show-much less establish-how the Senate acted whimsically, capriciously or arbitrarily, out of malice, ill will or personal bias in deciding not to instantly convene as an impeachment court as soon as the House filed the Articles of Impeachment.

Thus, the Senate did not commit grave abuse of discretion since (1) it had begun complying with its constitutional duty by preparing itself to conduct the impeachment trial, and (2) the Constitution itself does not provide any specific period when the Senate must start the actual trial.

Nevertheless, the term "forthwith" must ever remain in the Senate's consciousness when it is called on to exercise its constitutional duty to convene as an impeachment court. While the Constitution does not precisely fix the date when the trial must proceed, the Senate must not unduly delay the conduct of the trial, lest we render meaningless the Constitution's mandate that "[p]ublic officers...must, at all times, be accountable to the people."^[116]

ACCORDINGLY, the Petition for Mandamus is DISMISSED.

SO ORDERED.

Gesmundo, C.J., Hernando, Lazaro-Javier, Inting, Gaerlan, Rosario, Dimaampao, Marquez, and Kho, Jr., JJ., concur. 
Leonen, SAJ., see concurring and dissenting opinion.
Caguioa,^* J., no part.
Lopez,^{* *} J., on leave, but left a concurring vote and opinion.
Singh, J., see separate opinion.
Villanueva, J., see separate concurring opinion.

^** On leave, but left a concurring vote and opinion.

^[1] Rollo, pp. 3-27.

^[2] Id. at 4-13.

^[3] Id. at 4.

^[4] Id. at 38-40. Petitioner attached printouts from these articles online: (1) Victoria Tulad, ABS-CBN News, Senate formally receives articles of impeachment vs VP Sara Duterte from House, available at https://www.abs-cbn.com/news/nation/2025/2/5/senate-formally-receives-articles-of-impeachment-vs-vp-sara-duterte-from-house-1910 (last accessed on June 13, 2025), (2) Bonz Magsambol, Rappler, Escudero: No Senate impeachment trial during session break, available at https://www.rappler.com/philippines/escudero-response-no-senate-impeachment-trial-session-break/ (last accessed June 13, 2025); (3) Wilnard Bacelonia, Philippine News Agency, Senate makes Vice President Sara impeachment complaint public, available at https://www.pna.gov.ph/articles/1243726 (last accessed June 13, 2025).

^[5] Id. at 15.

^[6] Id. at 14.

^[7] Id. at 15.

^[8] Id. at 22-23.

^[9] Id. at 85.

^[10] Id. at 89-96.

^[11] Id. at 97-100.

^[12] Id. at 102.

^[13] Id. at 103-173.

^[14] Id. at 103-107.

^[15] Id. at 109-110.

^[16] Id. at 111-116.

^[17] Id. at 116-122.

^[18] Id. at 122-133.

^[19] Id. at 174-183.

^[20] To justify his prayer, petitioner again quoted from articles posted online: (1) Amando Virgil D. Ligutan, Not out of time: Sara Duterte can still be impeached, RAPPLER, February 3, 2025, available at https://www.rappler.com/voices/thought-leaders/enough-time-impeach-sara-duterte/ (last accessed June 16, 2025); (2) Abogado.com.ph, Ex-SC Justice Adolf Azcuna,: Impeachment trial must proceed despite Senate recess, ABOGADO, February 10, 2025, available at https://abogado.com.ph/ex-sc-justice-adolf-azcuna-impeachment-trial-must-proceed-despite-senate-recess/ (last accessed June 16, 2025); and (3) June 2, 2025, 7:21 a.m. post on Facebook by Juan Luna Blog, available at https://www.facebook.com/share/p/18hxfFbRVu/ (last accessed June 16, 2025).

^[21] Id. at 18.

^[22] See Municipality of Payao, Zamboanga Sibugay v. Municipality of Imelda, Zamboanga Sibugay, 905 Phil. 1046, 1052 (2021) [Per J. J. Lopez, Third Division].

^[23] Abueva v. Wood, 45 Phil. 612 (1924) [Per J. Johnson, Second Division].

^[24] See Estandarte v. People, 569 Phil. 465 (2008) [Per J. Austria-Martinez, Third Division]. (Citations omitted)

^[25] 392 Phil. 618 (2000) [Per J. Kapunan, En Banc].

^[26] See David v. Macapagal-Arroyo, 522 Phil. 705, 757-758 (2006) [Per J. Sandoval-Gutierrez, En Banc].

^[27] 849 Phil. 120, 161-162 (2019) [Per J. Jardeleza, En Banc].

^[28] 506 U.S. 224 (1993).

^[29] 460 Phil. 830 (2003) [Per. J. Carpio-Morales, En Banc].

^[30] BLACK'S LAW DICTIONARY 796 (11th ed. 2019).

^[31] Adolf Azcuna, June 7, 2025, available at https://www.facebook.com/share/p/1YqAMQ2hZq/ (last accessed on October 7, 2025). See Mariel Celine Serqui a, Ex-SC justice Azcuna: Senate needs to start process for VP Sara impeachment trial, GMA NEWS ONLINE, June 8, 2025, available at https://www.gmanetwork.com/news/topstories/nation/948707/ex-sc-justice-azcuna-senate-needs-to-start-process-for-vp-sara-impeachment/story/ (last accessed on June 16, 2025); Rufa Cagoco-Guiam, Weaponizing 'forthwith' to ditch VP ™s trial, INQUIRER.NET, June 10, 2025, available at https://opinion.inquirer.net/183801/weaponizing-forthwith-to-ditch-vps-trial (last accessed on June 16, 2025).

^[32] 2 Phil. 676 (1902) [Per J. Ladd, En Banc].

^[33] 51 Phil. 796 (1928) [Per J. Malcolm, En Banc].

^[34] Citizens Bank, N.A. v. Gaskins, 567 P.3d 891 (Kan. Ct. App. 2025).

^[35] People v. K.W., 2024 NY Slip Op 24172, 84 Misc. 3d 788, 213 N.Y.S.3d 693 (Sup. Ct.) [Supreme Court of New York, New York County, May 7, 2024].

^[36] In re Champion, 600 B.R. 459 (Bankr. S.D. Ga. 2019) [United States Bankruptcy Court for the Southern District of Georgia, Dublin Division, March 28, 2019].

^[37] Foster v. Kan. Dep't of Revenue, 281 Kan. 368, 130 P.3d 560 (2006) [Supreme Court of Kansas, March 24, 2006].

^[38] Seger v. For Women, Inc., 2006-Ohio-4855, 110 Ohio St. 3d 451, 854 N.E.2d 188 [Supreme Court of Ohio, October 4, 2006].

^[39] State ex rel. Comm. for Charter Amendment Petition to Limit the use of Photo-Monitoring Devices in the City of Maple Heights v. City of Maple Heights, 2014-Ohio-4097, 140 Ohio St. 3d 334, 18 N.E.3d 426 [Supreme Court of Ohio, September l 9, 2014].

^[40] Rollo, pp. 103-107.

^[41] Id. at 145, 162.

^[42] Id. at 146.

^[43] Id. at 147.

^[44] Id. at 148-151.

^[45] Id. at 152-161.

^[46] Id. at 163-165.

^[47] COMELEC Resolution No. 10999 (2024).

^[48] Concurrent Resolution No. 27 (2025), 19^th Congress, 3^rd Session, Concurrent Resolution Providing for the Adjournment Sine Die of the Third Regular Session of the Nineteenth Congress of the Philippines Not Later Than Twelve O'Clock Midnight, Today, Wednesday, June 11, 2025.

^[49] Justice Inting manifested this view during the deliberations of the Court.

^[50] G.R. Nos. 278353 and 278359, July 25, 2025 [Per S.A.J. Leonen, En Banc].

^[51] Duterte v. House of Representative, G.R. Nos. 278353 and 278359, July 25, 2025 [Per SAJ Leonen, En Banc] at 68-69. This pinpoint citation refers to the copy of the Decision uploaded to the Supreme Court website.

^[52] 87 Phil. 29 (1950) [Per J. Ozaeta, En Banc].

^[53] 586 Phil. 135 (2008) [Per J. Leonardo-De Castro, En Banc].

^[54] Id. at 196.

^[55] 835 Phil. 451 (2018) [Per J. Gesmundo, En Banc].

^[56] 835 Phil. 451, 469 (2018) [Per J. Gesmundo, En Banc].

^[57] David v. Macapagal-Arroyo, 522 Phil. 705, 753 (2006) [Per J. Sandoval-Gutierrez, En Banc].

^[58] 839 Phil. 807 (2018) [Per J. Leonen, Third Division].

^[59] Id. at 819.

^[60] Estrada v. Desierto, 406 Phil. 1, 29 (2001) [Per J. Puno, En Banc].

^[61] Id. at 30.

^[62] Id.

^[63] Id.

^[64] I Journal, Senate, Impeachment Trial of President Joseph E. Estrada 19 (November 28, 2000).

^[65] Id.

^[66] Estrada v. Desierto, 406 Phil. 1, 31 (2001) [Per J. Puno, En Banc].

^[67] Id.

^[68] Id.

^[69] Id. at 32.

^[70] Id. at 33.

^[71] Id.

^[72] Id. at 34.

^[73] Id.

^[74] Id. at 37.

^[75] 2 Congressional Record, 15^th Congress, Second Regular Session 11 (December 12, 2011).

^[76] Corona v. Senate et al., 691 Phil. 156, 159 (2012) [Per J. Villarama, Jr., En Banc].

^[77] Id.

^[78] Record of the Senate Sitting As An Impeachment Court 1 (December 14, 2011).

^[79] Id. at 2.

^[80] Id. at 4.

^[81] Corona v. Senate et al., 691 Phil. 156, 159 (2012) [Per J. Villarama, Jr., En Banc].

^[82] Id. at 162.

^[83] Id. at 162-163.

^[84] Id. at 163.

^[85] Record of the Senate Sitting As An Impeachment Court 6 (January 16, 2012).

^[86] Corona v. Senate et al., 691 Phil. 156, 167 (2012) [Per J. Villarama, Jr., En Banc].

^[87] Record of the Senate Sitting as an Impeachment Court 12-13, 24 (February 13, 2012).

^[88] Record of the Senate Sitting as an Impeachment Court 54-57 (February 28, 2012).

^[89] Record of the Senate Sitting as an Impeachment Court 32 (March 12, 2012), 31 (May 25, 2012).

^[90] Record of the Senate Sitting as an Impeachment Court 81 (March 22, 2012).

^[91] Record of the Senate Sitting as an Impeachment Court 1 (May 7, 2012).

^[92] Record of the Senate Sitting as an Impeachment Court 5-34 (May 22, 2012).

^[93] Record of the Senate Sitting as an Impeachment Court 6 (May 23, 2012).

^[94] Record of the Senate Sitting as an Impeachment Court 32 (May 25, 2012).

^[95] Record of the Senate Sitting as an Impeachment Court 4-29 (May 28, 2012).

^[96] Record of the Senate Sitting as an Impeachment Court 4-39 (May 29, 2012).

^[97] Record of the Senate Sitting as an Impeachment Court 40 (May 29, 2012).

^[98] Record of the Senate Sitting as an Impeachment Court 3 (May 29, 2012).

^[99] G.R. Nos. 278353 and 278359, July 25, 2025 [Per S.A.J. Leonen, En Banc].

^[100] Journal, Senate, 20^th Congress, Session No. 6, p. 35. (August 6, 2025).

^[101] G.R. Nos. 278353 and 278359, January 28, 2026 [Per S.A.J. Leonen, En Banc].

^[102] Concurrent Resolution No. 9 (2011), 15^th Congress, 2^nd Regular Session, Concurrent Resolution Providing for the Legislative Calendar for the Second Regular Session of the Fifteenth Congress of the Philippines gave the following dates for commencement, adjournment, and resumption of sessions:

1.	Commencement of Session	-	July 25, 2011 to October 14, 2011
2.	Adjournment of Session	-	October 15, 2011 to November 13, 2011
3.	Resumption of Session	-	November 14, 2011 to December 16, 2011
4.	Adjournment of Session	-	December 17, 2011 to January 15, 2012
5.	Resumption of Session	-	January 16, 2012 to March 23, 2012
6.	Adjournment of Session	-	March 24, 2012 to May 6, 2012
7.	Resumption of Session Sine Die Adjournment	-	May 7, 2012 to June 7, 2012
8.	Adjournment of Session	-	June 8, 2012 to July 22, 2012

^[103] Adopted Concurrent Resolution No. 22 (2024), 19^th Congress, 3^rd Regular Session, Concurrent Resolution Providing for the Legislative Calendar for the Third Regular Session of the Nineteenth Congress of the Philippines gave the following dates for commencement, adjournment, and resumption of sessions::

1.	Commencement of Session	-	July 22, 2024 to September 27, 2024
2.	Adjournment of Session	-	September 28, 2024 to November 3, 2024
3.	Resumption of Session	-	November 4, 2024 to December 20, 2024
4.	Adjournment of Session	-	December 21, 2024 to January 12, 2025
5.	Resumption of Session	-	January 13, 2025 to February 7, 2025
6.	Adjournment of Session	-	February 8, 2025 to June 1, 2025
7.	Resumption of Session (Sine Die Adjournment )	-	June 2, 2025 to June 13, 2025
8.	Adjournment of Session	-	June 14, 2025 to July 27, 2025

^[104] Journal, Senate, 15^th Congress, Session No. 43, 758, 760, and 771 (December 14, 2011).

^[105] Estrada v. Desierto, 406 Phil. 1, 30 (2001) [Per J. Puno, En Banc]. The Senate had to first create its own rules on impeachment trials. See Jess Diaz, Estrada impeached PHIL. STAR, November 14, 2000, available at https://www.philstar.com/headlines/2000/11/14/88756/estrada-impeached (last accessed on June 18, 2025).

^[106] Session No. 55, 19^th Congress, Senate, Third Regular Session. See https://www.youtube.com/watch?v=0407aKdpiQQ (Last accessed October 7, 2025); https://web.senate.gov.ph/photo_release/2025/0610_09.asp (Last accessed October 7, 2025). As of date, the records of Session No. 55 has not yet been uploaded to the Senate website.

^[107] Journal, Senate, 20^th Congress, Session No. 6, p. 35, (August 6, 2025). The Senate, as a plenary body and not as an Impeachment Court, voted to send the Articles of Impeachment to its archives.

^[108] The walkout of the prosecution panel on January 16, 2001 halted the impeachment trial of former President Estrada and precipitated People Power II or EDSA Dos. The technical date for the end of the impeachment trial was on February 7, 2021, when the Senate recognized that the Impeachment Court became functus oficio.

^[109] I. When the Senate receives articles of impeachment pursuant to Article XI, [secs. 2 and 3] of the Constitution, the President of the Senate shall inform the House of Representatives that the Senate shall take proper order on the subject of impeachment and shall be ready to receive the prosecutors on such time and date as the Senate may specify. (Emphasis added.)

^[110] II. When the President of the Philippines is on trial, the Chief Justice of the Supreme Court shall preside but shall not vote. Notice shall be given to him by the President of the Senate of the time and place fixed for the consideration of the articles of impeachment, with a request to attend. The Chief Justice shall be administered the oath or affirmation, prescribed under these Rules, by the President of the Senate and shall preside over the Senate during the consideration of said articles and upon the trial of the person impeached.

The President of the Senate shall preside in all other cases of impeachment and, for that purpose, placed under the prescribed oath or affirmation by any person authorized by law to administer an oath. (Emphasis added.)

^[111] III. Before proceeding to the consideration of the articles of impeachment, the Presiding Officer shall administer the prescribed oath or affirmation to the Members of the Senate then present and to the other Members of the Senate as they shall appear, whose duty it shall be to take the same.

Upon presentation of the articles to the Senate, the Senate shall specify the date and time for the consideration of such articles. Unless the Senate provides otherwise, it shall continue in session from day to day (except Saturdays, Sundays, and nonworking holidays) until final judgment shall be rendered, and so much longer as may, in its judgment, be necessary.

Senators shall observe political neutrality during the course of the impeachment trial. "Political neutrality" shall be defined as exercise of public official's duty without unfair discrimination and regardless of party affiliation or preference. (Emphasis added.)

^[112] Francisco, Jr. v. House of Representatives, 460 Phil. 830, 884 (2003) [Per J. Carpio-Morales, En Banc].

^[113] National Grid Corporation of the Philippines v. Manila Electric Company, G.R. No. 239829, May 29, 2024 [Per J. Zalameda, First Division].

^[114] S.A.J. Leonen, Reflections, pp. 15-16.

^[115] Almario v. Executive Secretary, 714 Phil. 127, 168 (2013) [Per J. Leonardo-Castro, En Banc].

^[116] CONST., art. XI, sec. 1.