The one-year bar rule in Philippine impeachment proceedings is a constitutional safeguard designed to prevent the harassment of impeachable officials and to ensure the efficient functioning of the legislative branch. This rule is expressly provided in Section 3(5), Article XI of the 1987 Constitution (1987):

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

This provision means that once an impeachment proceeding has been initiated against an official, no other impeachment proceeding can be commenced against the same official within the next twelve months.

Rationale Behind the Rule

The Supreme Court has explained that the one-year bar serves two primary purposes:

To protect high-ranking officials from undue or too frequent harassment through repeated impeachment complaints.
To allow the legislature to focus on its principal task of lawmaking, as impeachment proceedings are time-consuming and could otherwise paralyze legislative work.

As articulated in Gutierrez v. House of Representatives Committee on Justice (2011):

“The purpose of the one-year bar is two-fold: ‘to prevent undue or too frequent harassment; and to allow the legislature to do its principal task [of] legislation.’ … The impeachable officer should defend himself in only one impeachment proceeding, so that he will not be precluded from performing his official functions and duties. Similarly, Congress should run only one impeachment proceeding so as not to leave it with little time to attend to its main work of law-making.” — Gutierrez v. House of Representatives Committee on Justice (2011)

When Is an Impeachment Proceeding “Initiated”?

The Supreme Court, in Francisco, Jr. v. House of Representatives (2003), clarified that an impeachment proceeding is deemed “initiated” upon the referral of a verified complaint to the House Committee on Justice. This interpretation prevents the circumvention of the one-year bar by the mere filing of multiple complaints without formal referral.

This doctrine was reaffirmed in Gutierrez v. House of Representatives Committee on Justice (2011), where the Court emphasized that the bar applies to the initiation of proceedings, not merely the filing of complaints.

Application and Enforcement

The Supreme Court has consistently enforced the one-year bar rule to prevent successive impeachment complaints within a year. In Francisco, Jr. v. House of Representatives (2003), the Court declared a second impeachment complaint against Chief Justice Davide as unconstitutional because it was initiated within one year from the first.

Summary Table: Key Doctrines on the One-Year Bar Rule
PRINCIPLE/DOCTRINE SOURCE
One-year bar on impeachment 1987 Constitution, Art. XI, Sec. 3(5)
“Initiation” means referral to committee Francisco, Jr. v. House of Representatives (2003); Gutierrez (2011)
Rationale: prevent harassment, allow legislation Gutierrez (2011)

Conclusion

The one-year bar rule is a critical constitutional mechanism that balances the need for accountability of high officials with the need to protect them from political harassment and to ensure legislative efficiency. The Supreme Court’s consistent interpretation—most notably in Francisco, Jr. v. House of Representatives (2003) and Gutierrez v. House of Representatives Committee on Justice (2011)—anchors the rule’s application in both letter and spirit.