Case Digest (G.R. No. 254753) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Angel G. Naval v. Commission on Elections and Nelson B. Julia (G.R. No. 207851, July 8, 2014), petitioner Angel G. Naval had served as a Member of the Sangguniang Panlalawigan of Camarines Sur’s Second Legislative District for two consecutive terms (2004–2007 and 2007–2010). On October 12, 2009, Republic Act No. 9716 reapportioned Camarines Sur’s districts, carving eight of the old Second District’s ten towns into a newly renamed Third District while creating a distinct new Second District. In the 2010 and 2013 elections, Naval was elected and served as Provincial Board Member for the Third District. Respondent Nelson B. Julia filed before the COMELEC in October 2012 a petition to cancel Naval’s Certificate of Candidacy (COC) under Section 78 of the Omnibus Election Code, alleging that Naval had already served three consecutive terms and thus was ineligible for a fourth. On March 5, 2013, the COMELEC Second Division granted Julia’s petition and cancelled Naval’s COC, finding Case Digest (G.R. No. 254753) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Service and Reapportionment
- Angel G. Naval served as Member of the Sangguniang Panlalawigan (Provincial Board) of Camarines Sur, Second District, for two consecutive terms (2004–2007; 2007–2010).
- Republic Act No. 9716 (approved October 12, 2009) reapportioned Camarines Sur into five districts by:
- Carving out eight of the ten towns of the old Second District and renaming them as the Third District (Naga City, Pili, Ocampo, Camaligan, Canaman, Magarao, Bombon, Calabanga).
- Creating a new Second District from Gainza, Milaor (old Second District) and five towns from the old First District.
- Renaming the remaining districts without changing their composition (First, Fourth and Fifth Districts).
- Electoral Challenge
- Naval ran again and won as Board Member of the new Third District in 2010 and sought re-election in 2013.
- Nelson B. Julia filed a petition on October 29, 2012 under Section 78 of the Omnibus Election Code to cancel Naval’s 2013 Certificate of Candidacy, alleging violation of the three-term limit for local officials (Art. X, Sec. 8, 1987 Constitution; Sec. 43(b), LGC).
- COMELEC Second Division (Resolution March 5, 2013) cancelled Naval’s COC; COMELEC En Banc (Resolution June 5, 2013) denied his motion for reconsideration.
Issues:
- Did the reapportionment and renaming of districts reset Naval’s term count, allowing him to run in the “new” Third District after serving three consecutive terms?
- Does Naval’s candidacy for a fourth consecutive term, now as representative of the renamed Third District, violate the constitutional and statutory three-term limit for local elective officials?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)