SOCRATES V.

COMELEC
GR 154512 (November 12, 2002)

FACTS:
Mark David Hagredon served as a mayor of the the city of Puerto Princesa for three consecutive
full terms. Because of the three-term limit principle, Hagredon did not run for the same position
in the 2001 elections in which Socrates ran and won. The incumbent mayor, Socrates faced recall
proceedings midway into his term. Hagredon then filed for candidacy for mayor in the said
election. However, Socrates filed a petition to disqualify Hagredon on the ground that Hagredon
cannot run for Mayor for a fourth consecutive term, having been elected and having served as a
mayor of Puerto Princesa City for three consecutive full terms immediately prior to the instant
recall election for the same post.
ISSUE:
Whether or not Hagredon is disqualified to run under the three-term limit rule.
RULING: involuntary
The three-term limit rule for elective local officials is found in Section 8, Article X of the
Constitution, which states that: “Section 8. The term of office of elective local official, except
barangay officials, which shall be determined by law, shall be three years and no such official
shall serve for more than three consecutive terms. Voluntary renunciation of the office for a
length of time shall not be considered as an interruption in the continuity of his service for the
full term for which he was elected.” This three-term limit rule is reiterated in Section 43(b) of
RA No 7160, otherwise known as the Local Government Code which provides: “Section 43. (b)
No local elective official shall serve for more than three consecutive terms in the same position.
Voluntary renunciation of the office for any length of time shall not be considered as an
interruption in the continuity of service for the full term for which the elective official was
elected.”
The clear intent is that only consecutive terms count in determining the three-term limit rule.
After three consecutive terms, an elective local official cannot seek immediate reelection for a
fourth term. Any subsequent election such as a recall election is no longer covered by the
prohibition for two reasons: first, a subsequent election such as a recall election is no longer an
immediate reelection after three consecutive terms; second, the intervening period constitutes an
involuntary interruption in the continuity of service.