Impeachment procedure in the presidential system

Impeachment is one of the constitutional mechanisms that ensures the balance between the legislative and executive branches in countries governed by a presidential system. Its historical origins can be traced to England, with the first examples of the process emerging in the 14th century. After the United States gained independence, the framers of the Constitution closely followed the impeachment practices in England and adapted them. With the adoption of impeachment procedures in the U.S. Constitution, it became possible to accuse the President, Vice President, and senior government officials of treason, bribery, and other high crimes and misdemeanors. Impeachment in the U.S. Constitution is structured as a two-step process: the accusation phase takes place in the House of Representatives, while the trial phase is held in the Senate. Essentially a criminal accountability mechanism, impeachment in the U.S. has occasionally been used for political purposes. The impeachment mechanism is also present in the constitutions of Latin American countries governed by a presidential system. In this study, the impeachment processes in the constitutions of Brazil, Mexico, Bolivia, and Venezuela are examined. However, due to the insufficiently established democratic environment in these countries, the concepts and institutions unique to the presidential system are not fully functional. In Latin America, impeachment is often used as a tool to pressure the President to resign. In Türkiye, the procedure for holding the President criminally accountable was significantly altered by the constitutional amendment of 2017. Prior to the amendment, Turkish constitutions held the President criminally responsible only for treason. The lack of a definition of treason in the legislation led to years of debate on which crimes fell under its scope. Under the new Presidential Government System, the scope of the President's criminal responsibility has expanded.