**Facts:**
1. In the May 14, 2001 elections for Mayor of Lucena City, Raymundo M. Adormeo and incumbent Mayor Ramon Y. Talaga, Jr. were the only candidates.
2. Talaga, Jr. was first elected as Mayor in May 1992, served a full term, re-elected in 1995, served another full term, but lost in the May 1998 election to Bernard G. Tagarao.
3. In May 12, 2000, during a recall election, Talaga again won and served the unexpired term of Tagarao until June 30, 2001.
4. On March 2, 2001, Adormeo filed a petition challenging Talaga’s eligibility based on Section 8, Article X of the 1987 Constitution, which limits local officials to three consecutive terms.
5. The petitioner claimed that Talaga had already served three terms: 1992-1995, 1995-1998, and 2000-2001.
**Procedural Posture:**
1. On April 20, 2001, the Commission on Elections (COMELEC) First Division disqualified Talaga and canceled his certificate of candidacy.
2. Talaga filed a motion for reconsideration on April 27, 2001, contending that he had not served three consecutive terms due to his defeat in the 1998 election.
3. On May 9, 2001, the COMELEC en banc reversed the First Division and declared Talaga qualified to run for Mayor.
4. Talaga was proclaimed as Mayor on May 19, 2001.
5. Adormeo then sought relief from the Supreme Court through a petition for certiorari, arguing that the COMELEC committed grave abuse of discretion.
**Issues:**
1. Whether the COMELEC acted with grave abuse of discretion in declaring Talaga qualified to run for Mayor in the May 14, 2001 elections.
2. Whether Talaga’s service of the unexpired term constituted a full term under the three-term limit rule specified in Section 8, Article X of the Constitution and Section 43(b) of RA 7160.
**Court’s Decision:**
1. **On the COMELEC’s Discretion:** The Court found that the COMELEC did not act with grave abuse of discretion. The court affirmed COMELEC’s position that Talaga did not serve three consecutive terms.
2. **Interpretation of “Consecutive Terms”:** The Supreme Court held that Talaga’s defeat in the 1998 election constituted an interruption in his consecutive terms of service. For the three-term limit to apply, both continuous election and service for three full terms were required.
3. **Service of Unexpired Term:** Drawing upon precedents (Borja Jr. vs. COMELEC and Lonzanida vs. COMELEC), the Court ruled that Talaga’s service from May 2000 to June 2001 did not count as a full term. Thus, Talaga did not meet the criteria for disqualification under the three-term limit rule.
4. **Voluntary Renunciation Clause:** The Court clarified that the clause concerning voluntary renunciation did not apply as Talaga’s service was interrupted involuntarily (his loss in the 1998 election).
**Doctrine:**
1. An official must be elected and must serve three consecutive full terms for disqualification under Section 8, Article X of the 1987 Constitution to apply (Borja Jr. vs. COMELEC doctrine).
2. An unexpired term served following a recall election does not constitute a full term for the purpose of the three-term limit (Lonzanida vs. COMELEC doctrine).
**Class Notes:**
1. **Three-Term Limit:** The rule applies both to the election and completion of three consecutive full terms.
– *Reference:* Section 8, Article X of the 1987 Constitution, Section 43(b), RA 7160.
2. **Interruption of Term:** Involuntary interruptions, such as election defeats, are sufficient to break consecutive term service.
3. **Voluntary Renunciation:** Renouncing a term does not interrupt consecutiveness; this applies clearly to prevent office manipulation.
**Historical Background:**
– This decision is set against the backdrop of the Local Government Code and the principles of limiting terms to prevent the monopolization of political power.
– The ruling reiterates the balance between the need to prevent political monopoly and respecting the electorate’s choices, reflective of the deliberations and intentions during the framing of the 1987 Constitution.
**Conclusion:**
The Supreme Court upheld the COMELEC’s en banc decision and clarified the interpretation of the three-term limit rule, establishing that Talaga’s interrupted service due to his defeat in 1998 did not count toward consecutive terms, thus affirming his eligibility to run for Mayor in the 2001 elections.
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