Facts:

Ramon Talaga, Jr. served as mayor of Lucena City during terms 1992-1995 and 1995-1998. During the
1998 elections, Talaga lost to Bernard G. Tagarao. However, before Tagarao’s 1998-2001 term ended, a
recall election was conducted in May 2000 wherein Talaga won and served the unexpired term of
Tagarao until June 2001. When Talaga ran for mayor in 2001, his candidacy was challenged on the
ground that he had already served as mayor for three consecutive terms in violation of the three term-
limit rule. Comelec found Talaga disqualified to run for mayor. Talaga filed a motion for reconsideration
which Comelec granted. Talaga was then elected Mayor.

Issue:

Whether Talaga was disqualified to run as mayor given that he had already served two full terms and he
won in the 2000 recall elections.

Held:

The term limit for elective local officials must be taken to refer to the right to be elected as well as the
right to serve in the same elective position. Consequently, it is not enough that an individual has served
three consecutive terms in an elective local office, he must also have been elected to the same position
for the same number of times before the disqualification can apply.

For nearly two years Talaga was a private citizen. The continuity of his mayorship was disrupted by his
defeat in the 1998 elections. The time between his second term and the recall election is sufficient
interruption. Thus, there was no three consecutive terms as contemplated in the disqualifications in the
LGC.

Talaga only served two consecutive full terms. There was a disruption when he was defeated in the 1998
elections. His election during the 2000 recall election is not a continuation of his two previous terms
which could constitute his third term thereby barring him for running for a fourth term. Victory in the
2000 recall election is not the “voluntary renunciation” contemplated by the law. (Adormeo vs Comelec,
G.R. No. 147927, February 4, 2002)