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University of the Philippines College of Law

Subject | Professor
Case Digest
TOPIC: Term Limits
DOCTRINE: Voluntary renunciation of office is grounds for disqualitifcation;
involuntary renunciation is not
CASE Number (including date): GR No. 147927, Feb 4, 2002
CASE Name: Adormeo vs. Commission on Elections
Ponente Quisumbing J.
Petition for certiorari on COMELEC ruling that qualifies Ramon Talaga to run for
Petitioner (Raymundo Adormeo) and privae respondent (Ramon Talaga) were
the only ones who filed for candidacy for mayor in Lucena city on the
elections to be held on 9 May 2001.
Talaga served to consecutive terms (1992-1998). He was defeated in the
1998 elections to Bernard Tagarao but he won the recall elections in 12 May
2000 and served the unexpired term until 30 june 2001.
Adormeo filed a petition to deny due course and cancel certificate of
candidacy to Talaga for it is violative of Sec 8 Art. X of 1987 Constitution.
o Sec. 8. The term of office of elective local officials, except barangay
officials, which shall be determined by law, shall be three years and no
such official shall serve for more than three consecutive terms.

Voluntary renunciation of the office for any length of time

shall not be considered as an interruption in the
continuity of his service for the full term for which he was
elected (emphasis mine).

20 April 2001 COMELEC 1st division disqualified Talaga for having served 3
consecutive terms.
27 April 2001 Talaga filed motion for reconsideration stating that he did not
serve 3 consecutive terms of office which must amount to nine consecutive
2 May 2001 Adormeo filed opposition to motion saying serving an unexpired
term counts as serving a full term.
9 May 2001 COMELEC en banc ruled the disqualification must be lifted
because of he was not elected for three terms
o He was only installed as mayor because of the recall elections
o His loss in 1998 did not count in the 3 term rule
o He did not fully serve 3 terms

1. Whether or not Talaga was disqualified to run for mayor or Lucena


HELD (including the Ratio Decidendi)

NO: Sec. 8 Art X of the 1987 constitution clearly states that a person must
have served three consecutive terms in office. It cited Borja jr vs COMELEC
where the Court ruled that an official must have served and must have been
ELECTED for three consecutive times. The court highlights the last sentence
of sec. 8 which states that voluntary renunciation does not count as
interruption. Talagas loss in the 1998 elections does not count as voluntary
renunciation. He was removed from office because of an expiring term and an
electoral defeat. He did not serve a full ELECTED term.
Wherefore the petition is denied