Manila, Sept. 16 -- Continuous absence, failure to take the impeachment oath and voluntary inhibition emerged Wednesday as possible factors in determining who should be counted in the final voting base in Vice President Sara Duterte's impeachment trial.

During questioning by Senator-judge Risa Hontiveros, retired Chief Justice Reynato Puno said the Senate impeachment court could look at the reasoning in the 1949 Avelino v. Cuenco case when dealing with a senator who remains a member but continuously stays away from the proceedings.

Puno specifically cited the concept of a member being "beyond the coercive power" of the Senate, but stopped short of saying that such a senator should automatically be removed from the impeachment denominato...