Placeholder Impeachment™: Now With Extra Impunity Flavor – Brought to You by the Ghost of Oliver Lozano

How 15 Pages of Clippings Bought the Palace a Full Year of Constitutional Teflon

By Louis ‘Barok‘ C. Biraogo — January 21, 2026

MGA ka-kweba, countrymen, fellow martyrs of our beloved 1987 Constitution—welcome back to the Cave. While the House of Representatives is still on break and Malacañang pretends nothing is happening, a 15-page “masterpiece” is strolling through the corridors of Congress as if it has a life of its own. An impeachment complaint against President Ferdinand “Bongbong” Marcos Jr. (PBBM), filed by a previously obscure lawyer, Atty. Andre de Jesus, and endorsed by Rep. Jett Nisay—the very congressman currently under investigation by the Independent Commission for Infrastructure for his alleged “cong-tractor” sideline.

And do you know what? This entire drama is not about substance. It is not about drugs, the International Criminal Court (ICC), or ghost flood-control projects. It is about the meta-game—the game within the game, the procedural jujitsu that the powerful use to turn the very Constitution meant to protect the people into their shield.

***“Proof that the shortest distance between corruption and immunity is 15 sheets of recycled newsprint.”***

The Opening Gambit: The 15-Page Shield

On January 19, 2026, a complaint only 15 pages long—thinner than a student’s excuse letter—arrived at the Office of the Secretary General. No annexes, no Commission on Audit (COA) reports, no affidavits. Just news clippings and loud accusations: the President is allegedly a drug addict, supposedly ordered or enabled the “kidnapping” and surrender of former President Duterte to the ICC, and allegedly received kickbacks from infrastructure deals. Only one ground has even a hint of substance—the alleged misuse of unprogrammed appropriations in an infrastructure corruption scandal—but even that lacks any attached evidence.

The question on everyone’s lips: Why now? Why on the very first day this complaint can still be processed when sessions resume on January 26? Why not wait for stronger evidence?

Because this is a classic Lozano gambit. During the time of Gloria Macapagal-Arroyo, perennial impeachment filer Oliver Lozano filed “trash” complaints year after year to trigger the one-year bar rule under Article XI, Section 3(5) of the 1987 Constitution. The result? Even when the opposition had strong evidence, they were blocked for a full year. GMA was protected. Today, it feels like a rerun—only this time, the lead role belongs to Bongbong Marcos.

Who sounded the alarm first? Rep. Edgar Erice, who declared: “If they rush this and prevent other complaints from being filed, then the motive becomes clear.” Translation: If the House leadership (Speaker Dy and SecGen Garafil) fast-tracks referral to committee before others can file, this becomes The 15-Page Shield—a one-year forcefield for the President.

The Cast of Characters: No One Is Innocent Here

I will not sugarcoat it. Everyone has an agenda.

Atty. Andre de Jesus: Is he a genuine gadfly who truly believes his charges, or merely a convenient pawn in a larger game? His complaint reads like a term paper written overnight—pure allegations, zero proof. If he were serious, why not wait for stronger evidence? If not, then he is the new Oliver Lozano, knowingly or not.
Rep. Edgar Erice: Self-appointed guardian of the process. He says this complaint is “harmless” only if others file stronger versions this week. But why does he seem to dictate the timeline? Is he gatekeeping for the opposition, ensuring the next complaint comes from his camp? Or is he genuinely concerned that real accountability will be blocked?
Rep. Jett Nisay: The endorser. This congressman is currently in the hot seat over “cong-tractor” allegations—being investigated by the ICI for allegedly owning a construction firm while serving in Congress. And suddenly he endorses an impeachment complaint that includes grounds about infrastructure corruption? This is a defensive move, friends. It’s as if he’s saying: “If I’m corrupt, then everyone is corrupt!” Classic counter-punch.
House Leadership (Speaker Dy and SecGen Garafil): They hold the keys. If they rush referral to the Committee on Rules and then to Justice, the one-year bar is triggered. If they delay, others may still file and consolidation becomes possible. Their next move will reveal whether they fear a strong complaint or are confident they can quietly bury this one.
Malacañang: Dismissive, as expected. “This will not prosper,” they say. Classic strategy: treat it as noise while using procedural levers to kill it silently.
Duterte Faction: The ICC surrender allegation is the raw nerve here. This is UniTeam civil war, now constitutionalized. If anyone prodded de Jesus, it likely came from the camp seeking revenge against Marcos for the perceived betrayal of Digong.

No heroes here. Only strategists.

The Flawed Architecture: How the Shield Became a Weapon

The one-year bar rule was designed to protect officials from harassment—so they would not be distracted by repeated impeachment attempts. Today, it is being weaponized as a pre-emptive shield by the powerful. The most recent example? The Supreme Court’s 2025 decision overturning the impeachment of Vice President Sara Duterte, which was struck down because earlier weak complaints had already triggered the one-year bar. A cautionary tale: if we allow trash complaints to activate the bar, we will be playing procedural chess forever while real corruption slips away.

Substance versus gimmickry: Five of de Jesus’s grounds are pure smoke—drug use (how do you prove that without medical evidence?), kidnapping (a matter of foreign policy discretion), and so on. Only one ground has any real potential: unprogrammed appropriations and infrastructure kickbacks. Yet even that lacks evidence. The result? Procedural noise wins; substantive debate loses.

Possible pathways:

Death in Committee — Dismissed for lack of form and substance. Under Francisco v. House of Representatives (G.R. No. 160261, 2003), if it is not referred to the Justice Committee, it is not “initiated.” Safe for the opposition—but they must make noise.
Fast-tracked to trigger the bar — If House leadership rushes it, one year of impunity.
Consolidation — If others file quickly, the complaints can be consolidated per Gutierrez v. House of Representatives Committee on Justice (G.R. No. 193459, 2011). But speed is essential.

The Eternal Rerun: Doomed to Repeat Arroyo

This is not new. This is the Oliver Lozano Special—repeated ad nauseam from 2005 to 2008 to protect GMA. Today, same script, new cast. Are we condemned to this cynical cycle every administration? Apparently yes, as long as we treat the Constitution as a political survival playbook rather than an instrument of justice.

The Central Tragedy: Rule of Law Reduced to Procedural Chess

This is my thesis, friends: Impeachment—the Constitution’s ultimate accountability mechanism—has been reduced to a game of procedural chess. A 15-page trash complaint can potentially grant a sitting President a full year of constitutional impunity. And who loses? Ordinary Filipinos suffering from inflation, corruption, and infrastructure projects that exist only on paper.

We need judicial intervention. We need the Supreme Court to clarify: Can a basura complaint constitutionalize a year of impunity? It should not. There must be a minimum threshold of substance before the bar is triggered. Otherwise, accountability will remain a circus forever.

Call to Principle

Enough of the theater. Enough of the gimmicks. Impeachment is not a game—it is a sacred process for cleansing government. If the opposition is serious, they should slow down, gather real evidence, and file a strong complaint that cannot be easily dismissed. If this is a defensive move by the administration, they too will be exposed to the eyes of the people.

And to the President: If you have nothing to hide, why do you need a 15-page shield?

We must return public service to its true principle—pro-people, not pro-power. Because while they play chess in Congress, those of us outside continue to suffer poverty, corruption, and unfinished infrastructure.

Until the next chapter of our political telenovela.

Stay outraged, stay litigious, and never forgive procedural cowards.
The Constitution deserves better than this circus. So do you.
— Barok, still fuming in the cave