The Supreme Court has ruled that the three-term limit for local elective officials applies even when a municipality is converted into a city during their tenure. This means that if an official has already served three consecutive terms in a municipality, they cannot run for the same position in the newly created city, as the conversion does not reset the term count. The ruling ensures that the intent of the law, to broaden electoral choices and bring new individuals into politics, is upheld despite local government restructuring.
From Municipality to City: Does a Fresh Start Undo Term Limits?
This case involves Roberto Laceda, Sr., who served as Punong Barangay (Barangay Captain) of Barangay Panlayaan, Sorsogon. He held this position for three consecutive terms. Laceda aimed to run for a fourth term in the 2007 Barangay elections. However, Randy Limena filed a petition to disqualify Laceda. Limena argued that Laceda had already served the maximum three consecutive terms allowed by law. Laceda contended that his third term should not count. He claimed that it was his first term in the newly formed Sorsogon City after the merger of the municipalities of Sorsogon and Bacon. He argued the three-term limit should not apply, violating his right to run.
The COMELEC disqualified Laceda. It stated he had already served three consecutive terms. The Supreme Court upheld this decision. It emphasized the purpose of term limits is to encourage a wider pool of candidates and prevent the entrenchment of political dynasties. Laceda filed a motion for reconsideration. He insisted that the COMELEC erred in applying precedents related to municipal mayors. He claimed the precedent did not extend to the position of Punong Barangay. Laceda maintained his third term should be considered his first in the new city.
The Supreme Court disagreed. The Court considered Section 2 of Republic Act No. 9164, which mirrors Section 43 of the Local Government Code. The aim is to broaden the choices available to voters and introduce fresh faces into politics. It does this by disqualifying officials from seeking the same office after serving for nine consecutive years. The Court clarified that two conditions must be met for the three-term limit to apply. First, the official must have been elected to the same local government position for three consecutive terms. Second, the official must have fully served these three consecutive terms.
Although Sorsogon was converted into a city, Barangay Panlayaan’s territorial jurisdiction remained unchanged. Its inhabitants and voters remained the same. These voters had previously elected Laceda as their Punong Barangay for three consecutive terms. This ensured Laceda continued to exert authority over the same community. The Court looked to the case of Latasa v. COMELEC as precedent. This case established that a conversion from municipality to city does not interrupt the continuity of terms for the purpose of term limits.
The Supreme Court stated that the spirit of the law should be upheld. It found that the COMELEC acted correctly. It denied the motion for reconsideration, thereby affirming Laceda’s disqualification. This decision reinforces that conversions do not reset the term count, thereby serving the broader goal of ensuring no interruption of consecutive term limits.
FAQs
| What was the key issue in this case? | The key issue was whether the three-term limit for local officials applies when a municipality is converted into a city during their tenure, and the official seeks re-election in the same position. |
| What is the three-term limit rule? | The three-term limit rule, as stated in Section 2 of Republic Act No. 9164 and Section 43 of the Local Government Code, restricts local elective officials from serving more than three consecutive terms in the same position. |
| Did the conversion of Sorsogon into a city affect Laceda’s term count? | No, the conversion did not affect Laceda’s term count because the Supreme Court held that the territorial jurisdiction of Barangay Panlayaan remained the same, and the conversion did not interrupt Laceda’s term. |
| What was Laceda’s argument for running a fourth term? | Laceda argued that since the Municipality of Sorsogon was merged with the Municipality of Bacon to form Sorsogon City, his third term was actually his first in the new political unit, thus entitling him to run for two more terms. |
| What was the basis for disqualifying Laceda? | Laceda was disqualified because he had already served three consecutive terms as Punong Barangay of Panlayaan before Sorsogon became a city, and the conversion did not reset the term count. |
| What is the purpose of the three-term limit rule? | The purpose is to broaden electoral choices, prevent the entrenchment of political dynasties, and encourage a wider pool of candidates to participate in local governance. |
| What was the relevance of Latasa v. Commission on Elections to this case? | Latasa v. COMELEC was relevant as it involved a similar issue of municipal to city conversion and established the principle that such conversions do not interrupt the continuity of terms for the purpose of term limits. |
| What happens if an official voluntarily renounces office? | Voluntary renunciation of office for any length of time is not considered an interruption in the continuity of service for the full term for which the elective official was elected. |
In summary, the Supreme Court’s decision reinforces the principle that the three-term limit for local officials is strictly enforced, and transformations or restructuring of local government units do not provide a basis for circumventing this rule. The intention of promoting more diversity in governance remains central to this legal standard.
For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ROBERTO LACEDA, SR. VS. RANDY L. LIMENA, G.R. No. 182867, November 25, 2008
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