G.R. No. 147927; February 4, 2002
RAYMUNDO M. ADORMEO, petitioner, vs. COMMISSION ON ELECTIONS and RAMON Y. TALAGA, JR., respondents.

FACTS

Petitioner Raymundo M. Adormeo sought to disqualify private respondent Ramon Y. Talaga, Jr., the incumbent mayor, from running for Mayor of Lucena City in the May 14, 2001 elections. Adormeo contended that Talaga had already served three consecutive terms, violating the constitutional three-term limit. Talaga served as mayor from 1992 to 1998, having been elected in 1992 and re-elected in 1995. He then lost the 1998 election to Bernard Tagarao. However, Talaga won a recall election on May 12, 2000, and served the unexpired portion of Tagarao’s term until June 30, 2001. Adormeo argued that serving this unexpired term constituted a full third consecutive term under Section 8, Article X of the 1987 Constitution.
The COMELEC First Division initially disqualified Talaga, ruling he had served three consecutive terms. However, upon Talaga’s motion for reconsideration, the COMELEC En Banc reversed the decision. It held that Talaga was not elected for three consecutive terms because his loss in the 1998 election interrupted the continuity of his service. It further ruled that his victory in the recall election and service of the unexpired term did not constitute a full term for disqualification purposes. Talaga was subsequently proclaimed the elected mayor.

ISSUE

Whether the COMELEC En Banc acted with grave abuse of discretion in declaring Ramon Y. Talaga, Jr. qualified to run for mayor, thereby ruling that he had not served three consecutive terms as prohibited by the Constitution.

RULING

The Supreme Court dismissed the petition and affirmed the COMELEC resolution. The Court held that for the three-term disqualification rule to apply, two conditions must concur: (1) the official has been elected to the same position for three consecutive terms, and (2) the official has fully served three consecutive terms. The Court found both conditions absent.
First, Talaga was not elected for three consecutive terms. His electoral victories occurred in 1992, 1995, and 2000 (recall election). The 1998 election, which he lost, constituted a break in the electoral sequence. The recall election victory was a separate electoral event that did not create a third consecutive electoral win following his 1995 victory.
Second, Talaga did not fully serve three consecutive three-year terms. His service from the 2000 recall election until June 2001 was only for the unexpired portion of Tagarao’s term, which was less than the full three-year term prescribed by law. Citing Lonzanida v. COMELEC, the Court reiterated that an involuntary interruption in service—such as a defeat in an election—breaks the continuity of service for the purpose of the three-term limit. Talaga’s loss in 1998 was an involuntary severance from office, not a voluntary renunciation, which interrupted the continuity of his service. Therefore, he was not disqualified from running in the 2001 election.