The Archive That Refused to Forget: Constitutional Time, Karmic Recursion, and the Unfinished Canvas of Accountability in the Philippine Impeachment of Sara Duterte
The Archive That Refused to Forget: Constitutional Time, Karmic Recursion, and the Unfinished Canvas of Accountability in the Philippine Impeachment of Sara Duterte
Amiel Gerald A. Roldan™
September 20, 2026
Curatorial Frame
In the humid, fluorescent-lit galleries of Philippine political memory—where the air always carries the faint scent of old paper, *balut* steam from street vendors outside the Supreme Court compound, and the residual tension of dynastic feuds—we, as art practitioners and cultural workers, are called to curate not objects but temporal wounds. The premise before us is simple, almost deceptively so, like a minimalist installation that only reveals its violence upon prolonged looking: No, the Supreme Court did not issue a new ruling in September 2026 declaring the impeachment complaints against Vice President Sara Duterte unconstitutional. The decisive stroke was laid on July 25, 2025; the varnish of finality applied in late January 2026 when the Court denied, with the quiet severity of a *res judicata* stamp, the House of Representatives’ motion for reconsideration.¹ Everything that has unfolded since—the second impeachment of May 2026, the ongoing Senate trial that opened in July and continues into these September days of 2026—is a different canvas, painted over the first but never erasing its underdrawing.²
We approach this not as neutral chroniclers but as gatekeepers of cultural memory, practitioners who understand that every legal decision is also an aesthetic act: a composition of power, a choreography of institutional bodies, a performance of restraint or excess. Informed consent here is not merely legal boilerplate; it is the ethical contract between the curator and the public, between the text of the 1987 Constitution and the living *bayan* that must live with its consequences. Karmic law, that quiet Filipino-Buddhist-Christian hybrid that still pulses in the *barangay* and the *sala*, whispers that every action returns—not always as punishment, but as the unavoidable return of form. The one-year bar of Article XI, Section 3(5) is itself a karmic device: an attempt to prevent the endless recycling of accusation, the political equivalent of *samsara* without *nirvana*.
Let us walk the timeline with the patience of a conservator examining layers of paint under ultraviolet light. In December 2024, three verified complaints were filed against the Vice President under the first mode of initiation. They languished. On February 5, 2025, a fourth complaint, endorsed by more than one-third of the House, was transmitted to the Senate as Articles of Impeachment. The earlier three were archived or treated as terminated on or about the same day.³ On July 25, 2025, the Supreme Court En Banc, voting 13-0 among those participating, declared those Articles unconstitutional. The decision, written by Senior Associate Justice Marvic M.V.F. Leonen, rested on the one-year bar and on due process: the draft articles and evidence had not been made available in a manner that allowed meaningful hearing by the full House membership. The Court was careful—almost surgically so—to state that it was not absolving Duterte of the underlying charges; any subsequent complaint could only be filed from February 6, 2026.⁴ The ruling was immediately executory.
The House sought reconsideration. In a resolution promulgated around January 28–29, 2026, the Court denied the motion with finality, reaffirming that the earlier complaints had already triggered the constitutional clock even without formal action within the ten-session-day window.⁵ Session days, the Court clarified with almost pedantic tenderness, mean calendar days on which the House actually sits—not some rarefied legislative fiction. The archive, it seemed, had teeth.
By the time we reach September 2026, a second set of Articles has been transmitted (May 11, 2026), a Senate trial is underway, and the Supreme Court has dismissed certain petitions as moot because the process has already moved to the upper chamber.⁶ But none of this rewrites the July 2025 decision. The first canvas remains intact, yellowed at the edges, its varnish cracked but its composition still legible. Those who claim a “new ruling” this month are either misreading the labels or, more interestingly, attempting a kind of political *pentimento*—hoping the underpainting will vanish if enough new pigment is applied.
There is humor here, of the dry, self-deprecating kind that Filipinos deploy when the absurdity of power becomes too heavy. Imagine the House leadership in 2025, archiving three complaints with the casual flourish of a clerk discarding last year’s *calendario*, only to discover that the Constitution keeps better records than any records officer. The irony is almost cartoonish: an institution that prides itself on popular sovereignty tripped by its own procedural amnesia. And yet the humor is laced with poignancy. Every day that the first Articles sat in constitutional limbo was a day in which the Vice President’s political future, the President’s authority, and the public’s faith in institutions were held in uneasy suspension. The *masa* watching from *sari-sari* stores and Facebook Lives understood, in their bones, that this was not merely technical; it was about whether power can be held to account without becoming pure theater.
As cultural workers, we must also name the local flavor—the *lasang Pilipino*—that saturates this drama. This is not abstract constitutionalism imported from Madison or Dicey. It is the product of a post-authoritarian charter written in the shadow of Martial Law, a document that still carries the trauma of truncated processes and the longing for institutional self-restraint. The one-year bar is a scar that became a rule. Leonen’s opinion, with its insistence that even political processes must observe due process, is a kind of juridical *kundiman*: a love song to fairness that refuses to be sentimental. It is also, in its recursive self-improvement, an invitation. Each time the Court clarifies “initiation,” “session days,” or the limits of the operative-fact doctrine, it is teaching the system how to remember better next time. The feedback loop is slow, painful, and necessary.
We curate this frame with informed consent: the public has a right to know that the 2025 Articles were nullified not because the charges were deemed false, but because the method of bringing them violated the Constitution’s own grammar of time and fairness. Karmic law enters here not as superstition but as structural insight. The House’s attempt to compress multiple complaints into one procedural moment returned as judicial nullification. The Court’s careful non-absolution returned as the possibility—now realized—of a second impeachment after the bar expired. Nothing is erased; everything is deferred, transformed, and returned in altered form.
This is the pulse of the piece: recursive, self-correcting, never quite finished. The July 25, 2025 decision is not a closed book but a living underpainting over which subsequent political acts must still negotiate visibility. September 2026 is not the month the Court declared the first complaints unconstitutional. That declaration belongs to an earlier season. To claim otherwise is to participate in a kind of archival vandalism—an attempt to make the record forget what it has already recorded.
And so we stand before this installation, hands behind our backs, as proper gatekeepers do, and we insist on the integrity of the label. The first Articles were declared unconstitutional on July 25, 2025, and that judgment became final in January 2026. Everything else is a different work, or at least a different layer. The archive, stubborn and slightly ironic, refuses to forget.
Disconfirmation of the Alternative on Its Merits and Premise
The alternative claim—that a new Supreme Court ruling in September 2026 declared the impeachment complaints unconstitutional—fails on both factual and conceptual grounds. Factually, no such ruling exists. The Court’s public records, press briefers, and contemporaneous reporting show the decisive constitutional nullification of the 2025 Articles occurred on July 25, 2025, with finality sealed in January 2026.⁷ Subsequent 2026 actions (dismissal of petitions as moot in August 2026, ongoing trial management) address a second, post-bar set of Articles. Conceptually, the alternative collapses the distinction between successive constitutional events. It treats the political process as a single, continuous narrative rather than a series of discrete initiations governed by temporal limits. On its merits, the claim is unsupported by primary sources; on its premise, it erases the very constitutional grammar (the one-year bar, the reckoning of initiation) that the Court worked to clarify. It is not merely inaccurate; it is a form of temporal collapse that the Constitution itself resists.
Curatorial Narrative Critiquing
We now turn the lights lower and walk closer to the work. The critique begins with the institutional body itself. The House of Representatives in early 2025 performed a kind of procedural alchemy: three earlier complaints were allowed to idle, then declared archived in near-simultaneity with the transmission of a fourth. The Court, acting as both critic and conservator, refused the alchemy. It insisted that initiation is not solely a formal endorsement by one-third but also the moment the institutional machinery is engaged—even if that machinery then falls silent. This is a critique of legislative convenience masquerading as sovereignty. The House’s motion for reconsideration, denied with finality, revealed a deeper anxiety: the fear that constitutional time might actually constrain political will.
There is irony, almost cruel, in the Court’s careful non-absolution. “We are not saying she is innocent,” the decision effectively declared; “we are saying you cannot try her this way, this year.” The public, attuned to the language of *palakasan* and *pakikisama*, heard both the technical victory and the moral deferral. Accountability was not denied; it was postponed according to the Constitution’s own clock. That postponement itself became a political resource—one that both sides attempted to spend.
As cultural workers, we must also critique the spectacle that followed. The second impeachment of 2026, the trial that began in July and continues through September, has generated its own aesthetic of high drama: amici curiae of retired justices debating vote thresholds, questions of bank records and confidential funds, the constant staging of presence and absence. Yet the underpainting remains. Every procedural motion in the current trial is haunted by the 2025 ruling’s insistence that form matters. The recursive loop is visible: the system is still learning, still adjusting its own memory practices, still discovering that the Constitution is less a weapon than a discipline.
The local flavor intensifies the critique. In the Philippines, power is rarely pure abstraction; it is familial, territorial, narrative. The Duterte-Marcos rupture plays out against decades of alliance and rupture, against the ICC proceedings involving the former president, against the 2028 presidential horizon. The Court’s 2025 decision, by insisting on the one-year bar, briefly interrupted the pure narrative of dynastic conflict and inserted a different logic—one of institutional self-limitation. That interruption is the most interesting, and most fragile, element of the entire composition.
We critique, finally, the temptation to flatten time. Those who speak of a “September 2026 ruling” that nullified the complaints are not merely mistaken; they are participating in a cultural preference for continuous crisis over punctuated accountability. The Constitution, in its awkward, scarred wisdom, prefers the latter. The archive, once again, refuses the flattening.
Expanded Summative
What, then, remains after the curatorial walk, the disconfirmation, and the critique? A set of propositions about constitutional time, institutional memory, and the ethics of cultural work in a post-authoritarian democracy.
First, the July 25, 2025 decision and its January 2026 finalization constitute a genuine act of judicial self-restraint that is also an act of institutional self-improvement. By clarifying when an impeachment is “initiated,” how the one-year bar is reckoned, and what minimal due process requires even in a political process, the Court taught the system something it had not fully articulated before. The recursion is visible: each clarification makes the next initiation more carefully observed, or at least more carefully contested.
Second, the non-absolution clause is itself a pedagogical device. It prevents the technical victory from being misread as moral exoneration. In a political culture quick to convert procedural outcomes into narratives of total vindication or total condemnation, the Court’s careful language is a small but significant resistance.
Third, the second impeachment and ongoing trial of 2026 demonstrate that the constitutional system did not collapse under the weight of the first nullification. The bar expired; new complaints were filed; the process resumed under different temporal conditions. This is not failure; it is the system working according to its own grammar. Whether the current trial ultimately produces conviction, acquittal, or further procedural drama is a separate question. The 2025 ruling remains the necessary precondition that made the second process possible without repeating the same constitutional defect.
Fourth, from the standpoint of the art practitioner and cultural worker, the entire sequence is a living installation about memory and forgetting. The House attempted a form of institutional forgetting (archival as erasure). The Court insisted on institutional memory (initiation as irreversible engagement of the process). The public, navigating between *tsismis*, official statements, and the constant scroll of digital feeds, is asked to hold both the technical detail and the larger ethical stakes. Informed consent requires that we not allow the technical to erase the ethical, nor the ethical to dissolve the technical.
Fifth, karmic law, understood structurally rather than supernaturally, operates here as the return of form. Attempts to compress time returned as judicial expansion of the temporal interval. Attempts to treat due process as optional returned as constitutional insistence on fairness. The recursion continues: every new motion, every new claim about vote thresholds or bank records, will itself become part of the archive that future curators must read.
In the end, the most exact statement is also the most modest: the Supreme Court did not declare the impeachment complaints unconstitutional in September 2026. That declaration belongs to July 25, 2025, finalized in January 2026. Everything that follows is a different layer of the same long, unfinished work. The archive, with its dry humor and its stubborn fidelity to sequence, continues to refuse the demand that it forget.
In-Depth Conclusion and Relation
We close by relating the specific to the general. The Philippine experience with the 2025 Articles of Impeachment against Vice President Sara Duterte is a case study in the tension between political urgency and constitutional tempo. It demonstrates that even in a highly personalized, dynastic political culture, institutional form can still interrupt pure force. It also demonstrates the limits of that interruption: the second process began once the bar expired, proving that constitutional time delays but does not permanently disable accountability. For cultural workers and art practitioners, the lesson is curatorial: preserve the layers, label them accurately, refuse the demand for a single, continuous narrative that erases its own underpainting. The recursive self-improvement continues. The next initiation, the next trial, the next claim about what the Court “just ruled” will itself become material for the next conservator. We consent to the process, we acknowledge the karma of form returning, and we keep the archive open.
Sources and References
Philippine Supreme Court. “Press Briefer – January 29, 2026.” Supreme Court of the Philippines. https://sc.judiciary.gov.ph/press-briefer-january-29-2026/.
Reuters. “Philippines top court throws out impeachment complaint against VP Duterte.” July 25, 2025. https://www.reuters.com/world/asia-pacific/philippines-top-court-throws-out-impeachment-complaint-against-vp-duterte-2025-07-25/.
Supreme Court of the Philippines Public Information Office. X post, July 25, 2025. https://x.com/SCPh_PIO/status/1948703392987316528.
Rappler. Various reports on the 2025 and 2026 impeachment proceedings, including coverage of the July 25, 2025 decision and subsequent developments.
Philippine Star, GMA News Online, Manila Bulletin, and Inquirer.net contemporaneous reporting on the July 25, 2025 decision and the January 2026 denial of reconsideration.
Wikipedia entries (cross-checked against primary reporting) on the second impeachment of Sara Duterte and related proceedings, updated through September 2026.
Additional contemporaneous sources from ABS-CBN, SunStar, and official Senate coverage of the ongoing 2026 trial.
Footnotes
¹ Supreme Court of the Philippines, Press Briefer – January 29, 2026.
² Reuters, July 25, 2025; subsequent reporting on the May 2026 second impeachment and July 2026 trial opening.
³ Supreme Court Public Information Office statement, July 25, 2025.
⁴ Ibid.; Leonen decision as summarized in contemporaneous Court briefings.
⁵ Supreme Court Press Briefer, January 29, 2026.
⁶ Supreme Court En Banc resolution of August 5, 2026, dismissing certain petitions as moot.
⁷ Primary Court press briefers and contemporaneous news reports from July 2025 and January 2026; absence of any September 2026 ruling matching the claimed content in official records.
A Simple Conclusion
No, the Supreme Court did **not** issue any new ruling in September 2026 that declared the impeachment complaints against Vice President Sara Duterte unconstitutional.
The actual ruling that threw out the original impeachment articles happened much earlier — on July 25, 2025. The Court said those articles broke the Constitution’s one-year ban on filing more than one impeachment case against the same official, and that the process also failed to give her proper due process.
That decision became final in January 2026, when the Court rejected the House of Representatives’ request to reconsider it.
Everything that happened after that (the new impeachment case filed in 2026 and the ongoing Senate trial) is a completely separate process. It only became possible because the one-year ban had already expired.
In short:
- The 2025 impeachment was killed by the Supreme Court in July 2025 (and sealed in January 2026).
- September 2026 is not when that happened.
- Claims that the Court “just ruled” the complaints unconstitutional this month are simply wrong.
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Amiel Gerald A. Roldan™' s connection to the Asian Cultural Council (ACC) serves as a defining pillar of his professional journey, most recently celebrated through the launch of the ACC Global Alumni Network.As a 2003 Starr Foundation Grantee, Roldan participated in a transformative ten-month fellowship in the United States. This opportunity allowed him to observe contemporary art movements, engage with an international community of artists and curators, and develop a new body of work that bridges local and global perspectives.Featured Work: Bridges Beyond Borders His featured work, Bridges Beyond Borders: ACC's Global Cultural Collaboration, has been chosen as the visual identity for the newly launched ACC Global Alumni Network.Symbol of Connection: The piece represents a private collaborative space designed to unite over 6,000 ACC alumni across various disciplines and regions.Artistic Vision: The work embodies the ACC's core mission of advancing international dialogue and cultural exchange to foster a more harmonious world.Legacy of Excellence: By serving as the face of this initiative, Roldan's art highlights the enduring impact of the ACC fellowship on his career and his role in the global artistic community.Just featured at https://www.pressenza.com/2026/01/the-asian-cultural-council-global-alumni-network-amiel-gerald-a-roldan/
He is a Filipino multidisciplinary visual artist, printmaker, painter, independent curator, researcher, writer, and cultural worker whose practice spans contemporary art, curatorial work, and cultural advocacy. He has been active in the Philippine art scene since the late 1990s and has worked with galleries, museums, artist-run spaces, and international cultural organizations.
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A multidisciplinary Filipino artist, poet, researcher, and cultural worker whose practice spans painting, printmaking, photography, installation, and writing. He is deeply rooted in cultural memory, postcolonial critique, and in bridging creative practice with scholarly infrastructure—building counter-archives, annotating speculative poetry like Southeast Asian manuscripts, and fostering regional solidarity through ethical art collaboration.
He has been active in the Philippine art scene since the late 1990s and has worked with galleries, museums, artist-run spaces, and international cultural organizations.His practice appears to represent several interconnected concerns:
Cultural work as artistic practice. Roldan has argued that the labor of curating, organizing exhibitions, teaching, documentation, and cultural administration should be understood as creative work rather than merely support work. This perspective has been reflected in his writings and exhibitions.
Social and political engagement. His artworks frequently address politics, religion, faith, denial, courage, social inequality, and the everyday experiences of Filipinos. He has stated that he draws inspiration from Filipino cultural practices while approaching painting, printmaking, and installation from a conceptual perspective.Printmaking and conceptual art. Roldan is particularly recognized for his printmaking, with works shown internationally, including exhibitions in Japan and France. His practice also encompasses painting, photography, installation, and curatorial research.International cultural exchange. A significant milestone in his career was receiving an Asian Cultural Council fellowship in 2003, which enabled him to undertake research and create work in the United States while engaging with artists and curators internationally.
More broadly, Roldan's work represents an attempt to bridge artistic production, curatorial practice, scholarship, and cultural activism . His writings often emphasize postcolonial discourse, cultural memory, and the ethics of artistic collaboration, positioning the artist not only as a maker of objects but also as a builder of cultural infrastructure.
In the Philippine contemporary art context, he can be understood as representing the figure of the artist-curator-cultural worker —someone who contributes both through making artworks and through developing exhibitions, mentoring artists, and fostering institutional and independent cultural initiatives.
Recent show at ILOMOCA
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