Baste Drops “Ulo,” NBI Sees Assassination Plot, House Smells Impeachment Gold
Louis ‘Barok‘ C. Biraogo – April 20, 2026
THE foul perfume of Philippine political theater wafts through the air again. On one side of the ring: the Club Filipino stage where Davao Mayor Sebastian “Baste” Duterte, in full anti-corruption froth, declared to the RAGE Coalition faithful that “Tama na yan… Isang ulo lang naman ang kailangan namin, ang ulo ni Bongbong Marcos.” On the other: the National Bureau of Investigation (NBI) boardroom, where Director Melvin Matibag solemnly intones that the Bureau is “reviewing” the remark because, you know, mandate and presidential security and all that jazz—while conveniently spotting a “pattern” with Vice President Sara Duterte’s earlier “kill order” flourish. And hovering above it all, the House Committee on Justice’s subpoena duces tecum, dated March 31, 2026, ordering Matibag to appear April 14 and cough up every scrap of the NBI probe into Sara’s alleged threats.
Welcome to the War of the Ulo, ladies and gentlemen. Where metaphors get Mirandized, patterns get politicized, and the only head actually rolling is the rule of law’s.

Baste didn’t threaten the President. He handed the House its next three committee hearings on a silver platter — with garnish.
SPEECH OR SEDITION? BASTE’S ULO REMARK GETS THE NBI THIRD-DEGREE
Let us dissect the carcass with the precision of a Quezon City fiscal. Baste’s utterance—“Isang ulo lang naman ang kailangan namin”—is being eyeballed under Article 282 of Act No. 3815 (the Revised Penal Code) (Grave Threats) and Article 142 (Inciting to Sedition). The NBI, ever the dutiful guardian of Republic Act No. 10867 (National Bureau of Investigation Reorganization and Modernization Act)’s Section (g) mandate to investigate “threats to security or assaults against the persons of the President,” sees a literal bolo raised against the Chief Executive.
Yet the Duterte camp, with the weary sigh of a family that has heard this song before, insists it is “metaphor” and “maliciously taken out of logical context”—the exact same linguistic escape hatch Sara deployed in 2024 when she allegedly ordered an assassin to target Marcos, the First Lady, and Speaker Romualdez should she be killed. (See GMA News report on Sara’s statement and her subsequent clarification; research materials confirm identical defense.)
Under U.S. v. Perez (1922)—the jurisprudence the NBI’s own pattern theory unwittingly invokes—violent imagery like “bolos for cutting off the Governor-General’s head” was enough to convict for inciting sedition. Baste’s “ulo” lands in the same rhetorical neighborhood. But here is the exquisite hypocrisy both camps refuse to acknowledge: the Duterte dynasty built its brand on unapologetic, blood-curdling tough talk, only to cry “free speech!” the moment the tables turn. The Marcos-House alliance, meanwhile, suddenly discovers the RPC like a born-again Bible salesman, conveniently forgetting that selective prosecution is the oldest trick in the authoritarian playbook.
Apply the tests. Clear and Present Danger (the modern Philippine preference, per Chavez v. Gonzales and Bayan v. Ermita) demands imminent lawless action. Was there a mob storming Malacañang? A specific directive? A getaway car idling outside Club Filipino? Of course not. This was political theater, not a tactical brief. The Dangerous Tendency Doctrine—the looser, more authoritarian cousin—might let the NBI squeeze a case, but only by ignoring Article III, Section 4 of the 1987 Constitution, which enshrines freedom of speech as the lifeblood of democracy.
In the marketplace of ideas, Baste’s “ulo” is nothing more grotesque than the guillotine of the ballot box. The NBI’s sudden Puritanism is as credible as a congressman’s bank account.
PATTERN OR PARANOIA? MATIBAG’S “PATTERN” THEORY UNDER THE MICROSCOPE
Director Matibag’s “pattern” claim—Sara yesterday, Baste today, always the president’s “ulo”—is the legal equivalent of a conspiracy theorist pinning newspaper clippings to a corkboard. Republic Act No. 10867 (National Bureau of Investigation Reorganization and Modernization Act) empowers the NBI to protect national security, yes. But turning two family members’ rhetorical excesses into a prosecutable “pattern” smells less like diligent policing and more like a convenient narrative to feed the Palace’s impeachment machine.
If the Bureau is merely “mindful of the security of our president,” why the public announcement calibrated perfectly with the House subpoena? (Parenthetical aside: Nothing screams “independent investigation” like leaking your review schedule to GMA News right before the Justice Committee’s hearing.) This is not vigilantism; this is optics management dressed in a barong.
SUBPOENA SHTICK: HOUSE TURNS NBI INTO IMPEACHMENT ERRAND BOY
Enter the House Committee on Justice’s subpoena ad testificandum et duces tecum, demanding Matibag’s files on the very threats now being weaponized against Sara in her impeachment. Article VI, Section 21 grants Congress the power of inquiry, sanctified by Arnault v. Nazareno. But when that inquiry is laser-focused on NBI records already feeding an impeachment complaint that the panel has already declared “sufficient in form, substance, and grounds,” we are no longer in legislative oversight territory. We are in fishing-expedition-with-a-barong-tagalog territory.
Article XI impeachment is a political process, not a criminal trial. Yet here the House is using the NBI as its de facto investigative arm—subpoenaing the very agency whose probe could supply the “betrayal of public trust” ammunition. The one-year bar on impeachment complaints (upheld by the Supreme Court in 2025) has already been navigated; now they simply manufacture fresh grounds by subpoenaing the investigator himself. Elegant, if you like your rule of law with a side of partisan theater.
CHESSBOARD OF FOOLS: EVERY ACTOR’S PLAY FOR 2028
- Baste & Sara (The Duterte Camp): Martyrdom is the 2028 RAGE Coalition’s rocket fuel. Every subpoena, every “pattern” quote, every headline is another brick in the narrative of persecution. They are not defending free speech; they are auditioning for victimhood while keeping the family brand alive for the next election cycle.
- NBI / Director Matibag: Caught between the Executive anvil and the House hammer. Issue the subpoena and risk being called Palace lapdogs. Drop the case and risk being labeled soft on threats. The career-defining trap is exquisite.
- Marcos Administration & House Allies: This is not about “betrayal of public trust.” It is about neutralizing a 2028 rival by turning every Duterte utterance into Exhibit A. The impeachment complaints already cite the threats alongside confidential funds and unexplained wealth. The subpoena to Matibag is simply the cherry on the political sundae.
CATCH-22 IN THE ULO WAR: WHO DRAWS THE LINE ON POLITICAL TRASH TALK?
If the NBI acts too aggressively, it risks criminalizing dissent. If it does nothing, it risks normalizing threats against the presidency.
This is the Catch-22 no one wants to admit. The line between protecting the office and protecting the occupant’s feelings is drawn in quicksand. In a polarized state, the referee cannot be the NBI (Executive-aligned), nor the House (Marcos-dominated). The only institution with the constitutional spine to redraw that line is the Supreme Court—by finally clarifying the Brandenburg standard in Philippine context: true threats require intent, imminence, and likelihood of harm, not just colorful Tagalog hyperbole.
Until then, we remain trapped in this endless loop of weaponized outrage, where every “ulo” becomes a subpoena and every subpoena becomes another headline.
BAROK’S VERDICT: SUPREME COURT TO THE RESCUE—OR ELSE
- The NBI must have the institutional spine, if it finds no probable cause under Article 282, to say so publicly—subpoena be damned. Republic Act No. 6713 (The Code of Conduct and Ethical Standards for Public Officials and Employees) demands public officials act with justness and sincerity, not as errand boys for the ruling coalition.
- The Supreme Court should, at the earliest certiorari petition, draw a bright-line test: metaphorical guillotine of elections is protected speech; literal bolo of sedition is not. Political speech gets the highest protection; the State’s interest in presidential security does not extend to hurt feelings.
- Congress should stop treating the NBI as its private detective agency. Legislative inquiry is not a license for impeachment shopping.
The rule of law is not a cudgel for the powerful. It is supposed to be the shield for the unpopular. In the War of the Ulo, both sides have forgotten that. The only head that truly needs to roll is the one belonging to institutional hypocrisy.
Barok has left the cave.
Key Citations
A. Legal & Official Sources
- Act No. 3815. An Act Revising the Penal Code and Other Penal Laws. 1930, The LawPhil Project.
- Arnault v. Nazareno. G.R. No. L-3820, Supreme Court of the Philippines, 18 July 1950, The LawPhil Project.
- Bayan v. Ermita. G.R. No. 169838, Supreme Court of the Philippines, 25 Apr. 2006, The LawPhil Project.
- Chavez v. Gonzales. G.R. No. 168338, Supreme Court of the Philippines, 15 Feb. 2008, The LawPhil Project.
- The 1987 Constitution of the Republic of the Philippines. Official Gazette of the Republic of the Philippines, 1987.
- Republic Act No. 10867. An Act Reorganizing and Modernizing the National Bureau of Investigation (NBI), and Providing Funds Therefor. 2016, The LawPhil Project.
- Republic Act No. 6713. An Act Establishing a Code of Conduct and Ethical Standards for Public Officials and Employees. 1989, The LawPhil Project.
- U.S. v. Perez. G.R. No. 21049, Supreme Court of the Philippines, 22 Dec. 1923, The LawPhil Project.
B. News Reports
- Casilao Joahna Lei. “NBI Reviewing Baste Duterte Remarks, May Issue Subpoena.” GMA News Online, GMA Network, Apr. 2026.
- Panti, Llanesca T. “Marcos on Sara Duterte’s ‘Kill’ Remark: Such Criminal Plotting Should Not Pass.” GMA News Online, 25 Nov. 2024.
“House Panel Subpoenas NBI’s Matibag, VP Sara’s Lawyer for Next Impeachment Hearing.” GMA News Online, GMA Network, Apr. 2026.

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