The Supreme Court ruled that renaming a legislative district, without significantly altering its composition, does not reset the three-term limit for elected officials. This decision reinforces the principle that term limits aim to prevent the consolidation of political power, even when district boundaries are redrawn. The ruling clarifies that the focus is on the substance of representation rather than merely the name of the district, thus upholding the intent of the Constitution to ensure regular renewal in public office and prevent entrenchment.

Navigating Reapportionment: When Does a New District Truly Mean a Clean Slate?

The case of Angel G. Naval v. Commission on Elections and Nelson B. Julia (G.R. No. 207851) revolves around the complex interplay between reapportionment of legislative districts and the constitutional three-term limit for local elected officials in the Philippines. Angel G. Naval, a member of the Sangguniang Panlalawigan (Provincial Board) of Camarines Sur, sought re-election for a fourth consecutive term. The issue arose when the legislative district he represented underwent reapportionment, leading to the question of whether his previous terms should count towards the three-term limit in the newly configured district. This case hinges on interpreting the scope and application of Section 8, Article X of the 1987 Constitution and Section 43(b) of the Local Government Code (LGC), which imposes term limits on elective local officials.

From 2004 to 2010, Naval served two consecutive terms as a member of the Sanggunian for the Second District of Camarines Sur. In 2009, Republic Act (R.A.) No. 9716 was enacted, reapportioning the legislative districts in the province. Critically, the old Second District, where Naval previously served, was essentially renamed as the Third District. While a few towns were reassigned, the core constituency remained largely the same. In the 2010 elections, Naval ran and won as a member of the Sanggunian for the Third District, and again in 2013. Nelson B. Julia, a rival candidate, filed a petition with the Commission on Elections (COMELEC) to cancel Naval’s Certificate of Candidacy (COC), arguing that Naval had already served three consecutive terms, violating the constitutional term limit.

The COMELEC Second Division cancelled Naval’s COC, a decision upheld by the COMELEC en banc, leading Naval to file a Petition for Certiorari with the Supreme Court. The COMELEC argued that Naval was effectively running for the same government post for the fourth time, emphasizing the territorial jurisdiction and the electorate remained substantially the same. Naval countered that the Third District was a new district, distinct from the old Second District, thereby entitling him to run for two more terms. He invoked Article 94 of Administrative Order No. 270, highlighting that Sanggunian members are elected by districts, thus his election in 2013 was only his second term for the Third District.

The Supreme Court denied Naval’s petition, affirming the COMELEC’s resolutions. The Court emphasized that the three-term limit rule is an inflexible constitutional objective designed to prevent the accumulation of excessive political power. While acknowledging that reapportionment aims to equalize representation, the Court found that R.A. No. 9716 created a new Second District, but merely renamed the other four, including the district Naval sought to represent. The court stated: “Verba legis non est recedendum. The terms used in a legal provision to be construed compels acceptance and negates the power of the courts to alter it, based on the postulate that the framers mean what they say.”

The Court highlighted the importance of strict adherence to the term limit rule, stating that any exceptions must be viewed cautiously to prevent undermining the rule’s primary objective: to foster political renewal and broader participation. The Supreme Court underscored that the essence of elections in a democratic and republican state lies in ensuring the electoral process aligns with the fundamental principles of representation and renovation. This means the citizenry selects public functionaries who derive their mandate from the people and act on their behalf for a limited period, promoting responsible governance.

Justice Reyes writing for the Court cited Aldovino, Jr. v. COMELEC, emphasizing the inflexibility of the three-term limit rule:

As worded, the constitutional provision fixes the term of a local elective office and limits an elective official’s stay in office to no more than three consecutive terms. This is the first branch of the rule embodied in Section 8, Article X.

Further, the Court stated that, the intent to create a sole new district in that of the Second, while merely renaming the rest.

The Court reasoned that reapportionment should not serve as a loophole to circumvent term limits. The slight difference in population between the old Second District and the renamed Third District (less than 10%) did not alter the fundamental reality that Naval was, in substance, representing the same constituency for a fourth consecutive term. Allowing Naval to run again would undermine the constitutional mandate to achieve equality of representation among districts, as it would effectively permit him to hold the same office for an extended period, contrary to the drafters’ intent. The Court found no grave abuse of discretion on the part of COMELEC, upholding the presumed competence of the commission to resolve matters falling within its jurisdiction. Thus, maintaining the integrity of constitutional and statutory term limits.

FAQs

What was the key issue in this case?	The key issue was whether the reapportionment of legislative districts in Camarines Sur reset the three-term limit for Angel G. Naval, a member of the Sangguniang Panlalawigan. The Court needed to determine if Naval’s previous terms in the old Second District counted towards the limit in the renamed Third District.
What is the three-term limit rule?	The three-term limit rule, as enshrined in Section 8, Article X of the 1987 Constitution and Section 43(b) of the LGC, prohibits local elective officials from serving more than three consecutive terms in the same position. This rule aims to prevent the accumulation of excessive political power and foster political renewal.
What was the effect of R.A. No. 9716 on the districts of Camarines Sur?	R.A. No. 9716 reapportioned the legislative districts in Camarines Sur, creating a new Second District by merging towns from the old First and Second Districts. The old Second District, where Naval had previously served, was essentially renamed as the Third District, with only minor changes in its composition.
How did the Court interpret the term “rename” in R.A. No. 9716?	The Court interpreted the term “rename” in Section 3(c) of R.A. No. 9716 to mean that the lawmakers intended the old Second District to be merely renamed as the current Third District. The Court found no intention to create a completely new district, distinguishing it from the newly created Second District.
Why did the Court deny Naval’s petition?	The Court denied Naval’s petition because it found that the current Third District was essentially the same as the old Second District, where Naval had already served two terms. Allowing Naval to run again would undermine the three-term limit rule and create a dangerous precedent.
What is the significance of the Latasa v. COMELEC case?	The Latasa v. COMELEC case (463 Phil. 296) was mentioned to draw a parallel with the conversion of a municipality into a city, where the Court held that the change in status did not reset the term limit. In both cases, the Court looked at the substance of the representation rather than the mere change in designation.
What is reapportionment and what is its purpose?	Reapportionment is the realignment or change in legislative districts brought about by changes in population. Its primary purpose is to equalize population and voting power among districts, ensuring fair and equal representation.
What does the decision mean for other elected officials facing similar situations?	The decision reinforces the principle that renaming or slightly reconfiguring a district does not automatically reset the three-term limit for elected officials. The focus is on whether the core constituency and territorial jurisdiction remain substantially the same.

In conclusion, the Supreme Court’s decision in Naval v. COMELEC clarifies the application of the three-term limit rule in the context of reapportioned legislative districts. It underscores the importance of adhering to the constitutional objective of preventing the consolidation of political power and promoting political renewal. The ruling serves as a reminder that the substance of representation, rather than mere technicalities, should guide the interpretation of election laws.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ANGEL G. NAVAL, VS. COMMISSION ON ELECTIONS AND NELSON B. JULIA, G.R. No. 207851, July 08, 2014