The Dynamics of Constitutional Amendments in Indonesia and the Philippines: A Comparative Constitutional Law Study

Abstract

This study examines the dynamics of constitutional amendments in Indonesia and the Philippines through a comparative constitutional law approach, focusing on procedural, institutional, and structural aspects. The research employs a qualitative descriptive method based on the analysis of constitutional texts, legal frameworks, and relevant scholarly literature. The findings indicate that Indonesia adopts a centralised and formalised amendment process, in which authority is concentrated in a single constitutional body, resulting in a structured and uniform mechanism of constitutional change. In contrast, the Philippines utilises a multi-channel amendment framework that allows for legislative, convention-based, and participatory mechanisms, reflecting a more flexible constitutional structure. The comparison reveals that both countries maintain constitutionally regulated amendment procedures yet differ significantly in institutional design and procedural configuration. Indonesia emphasises procedural rigidity and institutional centralisation, while the Philippines demonstrates procedural plurality and flexibility. Despite these differences, both systems exhibit a commitment to constitutional continuity through established legal mechanisms. This study contributes to comparative constitutional scholarship by highlighting diverse models of constitutional amendment within the Southeast Asian context and providing a systematic understanding of how constitutional systems manage legal change.