MAYOR ABELARDO ABUNDO, SR., v.

COMELEC, ET. AL., G.R. No. 201716,

January 8, 2013
Political Law; The three-term limit rule for elective local officials; Elements. To constitute a
disqualification to run for an elective local office pursuant to the aforequoted constitutional and
statutory provisions, the following requisites must concur:
(1) that the official concerned has been elected for three consecutive terms;
(2) that he has fully served three consecutive terms.
Judging from extant jurisprudence, the three-term limit rule, as applied to the different factual
milieus has its complicated side.
In the instant case, the Court revisited and analyzed the various holdings and relevant
pronouncements of the Court on the matter.
The Supreme Court further held that there has, in fine, to be a break or interruption in the
successive terms of the official after his or her third term. An interruption usually occurs when
the official does not seek a fourth term, immediately following the third. Of course, the basic law
is unequivocal that a voluntary renunciation of the office for any length of time shall NOT be
considered an interruption in the continuity of service for the full term for which the elective
official concerned was elected. This qualification was made as a deterrent against an elective
local official intending to skirt the three-term limit rule by merely resigning before his or her
third term ends. This is a voluntary interruption as distinguished from involuntary interruption
which may be brought about by certain events or causes.