02/06/2026
The Barzaga Expulsion
The June 2, 2026 expulsion of Cavite 4th District Representative Francisco "Kiko" Barzaga by an overwhelming 265-to-14 vote by the House of Representatives in favor of the expulsion marks the second time in recent history that the House of Representatives has exercised its constitutional power of expulsion under Article VI, Section 16(3) of the 1987 Constitution.
Arnolfo "Arnie" Teves Jr., former Negros Oriental 3rd District Representative, was the first member of the House of Representatives to be formally expelled with an equally overwhelming vote of 265–to–3 following his prolonged unauthorized absences, an attempt to seek political asylum in Timor-Leste (construed as abandonment of office), and "indecent behavior" on social media while being sought for his alleged involvement in the assassination of Governor Roel Degamo.
In the case of now former Representative Barzaga, the House justified the move on the ground that his epeated acts, including disruptive conduct during proceedings, controversial social media posts targeting House leaders, and public accusations against fellow lawmakers which constituted a continuing pattern of "disorderly behavior."
Having already served two separate 60-day suspensions without modifying his conduct, the House Ethics Committee concluded that expulsion had become necessary to preserve institutional discipline and protect the integrity of the chamber.
At the heart of the controversy lies an interesting constitutional balancing between legislative autonomy and freedom of expression.
Supporters of the expulsion from the House of Representatives, no less, argue that expulsion is a disproportionately severe sanction that effectively nullifies the electoral mandate given by the people of Cavite's 4th District. They warn that using the broad and potentially elastic concept of "disorderly behavior" to remove a legislator for inflammatory speech, social media activity, or political grandstanding could chill dissent and empower legislative majorities to silence unpopular or opposition voices.
The majority, however, saw it differently, as Congress possesses broad authority to discipline its own members and that parliamentary privilege cannot be used as a shield for conduct that undermines the institution's ability to function.
At least in theory, should Barzaga, now a private citizen and potentially, a politician turned actor, challenge the decision before the Supreme Court, his petition would likely confront the political question doctrine. While the Court retains the power to review acts tainted by grave abuse of discretion, it has traditionally refrained from interfering in matters constitutionally committed to a co-equal branch.
Concomitantly, since the Constitution expressly grants each House the authority to punish and expel its members, judicial review would generally be limited to determining whether the House complied with constitutional requirements, particularly procedural due process and the two-thirds vote threshold.
Given that the House conducted ethics proceedings and secured 265 affirmative votes, well above the required constitutional threshold, the Supreme Court may view the merits of the expulsion as a nonjusticiable political question rather than a legal controversy.
Ultimately, the Barzaga expulsion underscores both the breadth of congressional disciplinary authority and the vulnerability of individual legislators when confronted by an overwhelming legislative majority. Whether viewed as a necessary defense of parliamentary decorum or an excessive sanction against political expression, the episode serves as a significant constitutional test of the balance between institutional self-preservation, democratic representation, and free political speech within the Philippine legislative system.
