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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.