The three-term limit rule provided by the Constitution is inflexible.

Here, Naval was elected by the same

inhabitants in the same territorial jurisdiction. While RA 9716 created a new second district for
Camarines Sur, it merely renamed the third district which elected Naval into the position. Hence, her
election for the year 2013 is not valid.
FACTS:
From 2004 to 2010, Angel Naval had been elected and had served as a member of Sanggunian,
Second
district, Camarines Sur. Sometime in 2009, RA 9716, which reapportioned the legislative districts of
Camarines, was enacted. Eight out of ten towns were taken from the second district of Camarines
Sur
to create a third district. The second district was composed of the remaining two towns, plus the
town of Gainza and Milaor from the first district. In the 2010 elections, Naval ran and won as a
member of the Sanggunian of the third district. In 2013, she ran again and was re-elected for the
same
position. When Naval’s election was question on the ground of the three-term rule, she argued that
she only served as a member of the Sanggunian for two terms. Her theory is that because of the
reapportionment of the province of Camarines Sur, she was, elected by another territorial
jurisdiction and by different inhabitants.
ISSUE:
Whether Naval’s election for the year 2013 is valid. (NO)