Title
Aldovino, Jr. vs. Commission on Elections
Case
G.R. No. 184836
Decision Date
Dec 23, 2009
Elected official suspended during third term; Supreme Court ruled preventive suspension does not interrupt term limit, disqualifying him from fourth term.

Case Digest (G.R. No. 227775)

Facts:

  • Parties and Context
    • Simon B. Aldovino, Jr., Danilo B. Faller and Ferdinand N. Talabong (petitioners) vs. Commission on Elections (COMELEC) and Wilfredo F. Asilo (respondent) before the Supreme Court en banc.
    • Asilo served as Lucena City councilor for three consecutive terms (1998–2001; 2001–2004; 2004–2007).
  • Preventive Suspension and Candidacy Challenge
    • In September 2005, the Sandiganbayan 4th Division preventively suspended Asilo for 90 days in connection with a criminal case.
    • On November 9, 2005, this Court lifted the suspension; Asilo resumed and completed his term.
    • For the 2007 election, Asilo filed his certificate of candidacy for a fourth term. The petitioners moved to cancel it, alleging violation of the three-term limit under Section 8, Article X of the Constitution and Section 43(b) of RA 7160.
    • The COMELEC Second Division (November 28, 2007) and the COMELEC en banc (October 7, 2008) ruled in Asilo’s favor, holding that the preventive suspension interrupted his third term and exempted him from the term limit.

Issues:

  • Does preventive suspension of an elected local official interrupt his term of office for purposes of the three-term limit rule under Section 8, Article X of the Constitution and Section 43(b) of RA 7160?
  • Is preventive suspension considered an “involuntary renunciation” of office as contemplated in Section 43(b) of RA 7160?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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