Title
Latasa vs. Commission on Elections
Case
G.R. No. 154829
Decision Date
Dec 10, 2003
Arsenio Latasa, after serving three terms as municipal mayor, sought re-election as city mayor post-Digos’ conversion. The Supreme Court ruled his candidacy invalid, upholding the three-term limit despite the municipality-to-city transition.

Case Digest (G.R. No. 154829)
Expanded Legal Reasoning Model

Facts:

  • Parties and Context
  • Petitioner: Arsenio A. Latasa, three-term municipal mayor of Digos (1992, 1995, 1998).
  • Respondents: Commission on Elections (First Division and en banc) and Romeo M. Sunga, rival candidate for Digos City mayor.
  • Chronology of Events
  • Republic Act No. 8798 converting Digos into a component city was ratified by plebiscite on September 8, 2000; under §53, Art. IX of the city charter, Latasa served as hold-over city mayor.
  • On February 28, 2001, Latasa filed his certificate of candidacy for city mayor, disclosing three consecutive municipal terms and declaring this his first run for city mayor.
  • On March 1, 2001, Sunga filed before COMELEC a petition to deny due course to and cancel Latasa’s certificate of candidacy for allegedly misrepresenting his eligibility. Latasa filed his answer on March 5, 2001; both parties submitted position papers on March 19, 2001.
  • On April 27, 2001, COMELEC’s First Division issued a resolution canceling Latasa’s certificate for violating the three-term limit; Latasa’s motion for reconsideration (filed May 4, 2001) remained unacted upon through election day.
  • Despite the pending motion, Latasa was proclaimed winner on May 17, 2001 (25,335 votes vs. Sunga’s 13,650) and was sworn in as mayor on July 1, 2001.
  • On August 27, 2002, the COMELEC en banc denied Latasa’s motion for reconsideration. Latasa then filed a petition for certiorari under Rule 65 before the Supreme Court.

Issues:

  • Main Issue
  • Whether Arsenio A. Latasa is eligible to run for mayor of the newly created City of Digos immediately after serving three consecutive terms as mayor of the Municipality of Digos, in light of the three-term limit in Article X, Section 8 of the Constitution.
  • Secondary Issue
  • Whether, upon Latasa’s eventual disqualification, the second-placer, Romeo M. Sunga, should be proclaimed mayor.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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