Administration critic and Liberal Party (LP) Chairperson Mamamayang Liberal (ML) Party-list Rep. Leila de Lima was among the solons who went to great lengths Tuesday, Feb. 3 to discredit the first impeachment complaint filed President Marcos.

De Lima took part in Tuesday's Committee on Justice hearing wherein the panel discussed at length whether or not the complaint filed by lawyer Andre de Jesus and subsequently endorsed by Pusong Pinoy Party-list Rep. Jett Nisay was sufficient in substance, based on the allegations and arguments it raised for the Chief Executive's ouster.

Among the five arguments for President Marcos' removal in office was his alleged receipt of kickbacks from anomalous and "ghost" flood control projects.

De Lima, a former Department of Justice (DOJ) secretary, assailed the De Jesus complaint for failing to cite specific details like dates, places, and persons involved; as well as presenting conclusions instead of hard facts.

"I just wonder, in light of the evidence uncovered in the multiple fora investigations conducted on the floor control scam, medyo kapos talaga sa allegation yung complaint (there complaint is lacking in terms of allegations)," she said.

"It seems overly complacent for the complainant to be sparing in his factual allegations as to establish the ground for impeachment. For me, madam chair, there is simply paucity of factual allegations. Again, this is insufficient," added the former senator.

De Lima also shot down the argument for impeachment in connection with the President’s alleged drug addiction. This mainly stemmed from Senator Imee Marcos' allegations against her brother.

"The recital of allegations to this ground is still insufficient in terms of showing the nexus--kasi yung po yung importante (because that's the important thing)--between the facts raised or alleged and betrayal of public trust," she said.

She added: "Public accusations of PBBM's addiction, Senator Imee's claim of PBBM's addiction, PBBM's refusal to submit to a drug test, and his silence on accusations of being an addict still does not constitute the factual allegations necessary to satisfy the legal exercise and the formulation of causes of action that, assuming they were all true, they establish the betrayal of trust."

De Lima stressed that the committee’s task at this stage was limited to determining whether a complaint meets the threshold of allegational sufficiency—not whether accusations were true, credible, or supported by conclusive evidence.

“Technically and strictly, and if we go by the standard set of the House Rules itself, the rules of procedure in impeachment proceedings, it’s supposed to be just, you just have to look at whether the complaint has a recital of facts constituting the impeachable offense charged and determinative of the jurisdiction of this committee."

She noted that sufficiency in substance required more than sweeping conclusions on the part of the subject complaint.

“When we talk about substance, it refers to first whether the complaint alleges ultimate facts that if hypothetically admitted would constitute an impeachable offense," said the one-time senator.

De Lima outlined specific standards under the House Rules, and emphasized that allegations must be factual, coherent, and clearly tied to a constitutional ground for impeachment.

“A complaint is sufficient in substance when it, number one, narrates specific acts or omissions, not mere conclusions,” she said.

“Number two, it shows a nexus, a connection, between the acts complained of and an impeachable ground. Kailangan konektado ‘yung allegations of facts doon sa constitutional ground," the LP official said.

“Number three, should be intelligible and coherent, allowing the respondent to meaningfully answer. Number four, it is not purely speculative or opinion-based,” added De Lima.