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Senate President Pro Tempore Win Gatchalian during a Blue Ribbon Committee meeting on June 8, 2026 to reopen the investigation into anomalous government flood control projects.
Senate Social Media Unit via Facebook / Joseph B. Vidal
MANILA, Philippines — Official Senate records show that the Philippine Senate has a precedent of recognizing a 12-member quorum to conduct official business, Senate President Pro Tempore Win Gatchalian revealed.
Citing official Senate journals from 2008 to 2020, Gatchalian said previous Senate traditions support the validity of a 12-member threshold when the active membership of the chamber fluctuates, addressing doubts over recent legislative proceedings.
"Hindi natin pwedeng baguhin ang kasaysayan. Ang Senate records mismo ang nagpapatunay na hindi na bago ang nangyaring sesyon noong June 3 at ito ay lehitimo," Gatchalian said.
(We cannot change history. The Senate records themselves prove that what happened during the June 3 session is nothing new, and it is legitimate.)
The following were instances of a 12-man quorum in the Senate:
- 2008 and 2009: On May 21, 2008 and Feb. 11, 2009, a quorum of 12 members was declared out of a 23-senator chamber following the resignation of Sen. Alfredo Lim, who won the Manila mayoral race in 2007. During these sessions, Sen. Antonio Trillanes IV was under detention and unable to attend.
- 2010: On Sept. 29, 2010, the Senate again declared a valid quorum with 12 senators present out of 23 members after Sen. Benigno Aquino III vacated his seat to assume the presidency. Trillanes remained detained at the time.
- 2012: On May 8 and 15, 2012, official business was conducted with 12 senators present following Aquino’s earlier departure, as other members were either on sick leave, official missions, or arrived shortly after the initial roll call.
- 2015: The Senate adjusted its quorum base on May 5, 2015, when four senators were abroad and Sens. Juan Ponce Enrile, Bong Revilla, and Jinggoy Estrada were under detention. With only 12 members physically present, the presiding officer declared a valid quorum. An identical situation occurred a month later on June 2, 2015.
- 2020: Most recently, on May 23, 2020, a valid quorum was sustained with 12 senators present. During this period, Sen. Leila de Lima was under detention, while several other lawmakers were unable to physically attend the session.
Gatchalian issued the statement amid Sen. Alan Peter Cayetano’s insistence to retain the Senate leadership.
Cayetano is insisting that a 13-man quorum is needed to replace the Senate President and other committee chairmanships.
However, on the Senate website and during Gatchalian’s appointment on June 3, it was stated that he is the Senate President Pro Tempore.
Gatchalian’s position places him in the Senate leadership in the absence of a Senate President. In the current situation, Gatchalian was appointed following the arrival of Sen. Chiz Escudero, after the Cayetano-led bloc had not attended the Senate plenary since June 1.
The Gatchalian bloc also cited the Supreme Court case of Avelino vs. Cuenco, which recognized that the Senate may conduct business with a quorum based on available and functioning members.
The House of Representatives and Malacañang have also recognized Gatchalian’s leadership in the Senate, despite Cayetano’s insistence.
