G.R. No. 207851, July 08, 2014
ANGEL G. NAVAL, Petitioner, v. COMMISSION ON ELECTIONS AND NELSON B. JULIA, Respondents.
D E C I S I O N
Resolution2 (first assailed resolution) issued by the Second Division on March 5, 2013, in SPA No. 13-166 (DC), granting the petition filed by Nelson B. Julia (Julia), seeking to cancel the Certificate of Candidacy3 (COC) as Member of the Sangguniang Panlalawigan of Camarines Sur (Sanggunian) of Angel G. Naval (Naval), who is allegedly violating the three-term limit imposed upon elective local officials as provided for in Article X, Section 84 of the 1987 Constitution, and Section 43(b)5 of the Local Government Code (LGC); and
En Banc Resolution6 (second assailed resolution) issued on June 5, 2013, denying Naval’s Motion for Reconsideration7 to the Resolution dated March 5, 2013.
District Before the Enactment of
R.A. No. 9716
After the Enactment of
R.A. No. 9716
1st Libmanan, Minalabac, Pamplona, Pasacao, San Fernando, Del Gallego, Ragay, Lupi, Sipocot, Cabusao Del Gallego, Ragay, Lupi, Sipocot, Cabusao 2nd Naga City, Pili, Ocampo, Camaligan, Canaman, Magarao, Bombon, Calabanga,9Gainza, Milaor Libmanan, Minalabac, Pamplona, Pasacao, San Fernando, Gainza, Milaor 3rd Caramoan, Garchitorena, Goa, Lagonoy, Presentacion, Sangay, San Jose, Tigaon, Tinambac, Siruma Naga City, Pili, Ocampo, Camaligan, Canaman, Magarao, Bombon, Calabanga 4th Iriga City, Baao, Balatan, Bato, Buhi, Bula, Nabua Caramoan, Garchitorena, Goa, Lagonoy, Presentacion, Sangay, San Jose, Tigaon, Tinambac, Siruma 5th Iriga City, Baao, Balatan, Bato, Buhi, Bula, Nabua
[W]hen a candidate for public office swears in his COC that he is eligible for the elective posts he seeks, while, in reality, he knowingly lacks the necessary requirements for eligibility, he commits a false material misrepresentation cognizable under Section 78 of the [OEC].
x x x x
The Supreme Court[,] in the case of Lonzanida v. [COMELEC][,] detailed the important components of [Article X, Section 8 of the Constitution]:This Court held that the two conditions for the application of the disqualification must concur: 1) that the official concerned has been elected for three consecutive terms in the same local government post and 2) that he has fully served three consecutive terms. It stated:x x x The first requisite does not only describe a candidate who has been elected for public office for three consecutive terms. The candidate must have been elected in the same local government post. This connotes that the candidate must have been in the same elective position serving the same constituency who elected him to office for three consecutive terms.To recapitulate, 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. x x x
x x x x
The three-term limit rule was designed by the framers of the Constitution to prevent the monopoly of power centered only on a chosen few. The said disqualification was primarily intended to forestall the accumulation of massive political power by an elective local government official in a given locality in order to perpetuate his tenure in office. The framers also considered the necessity of the enhancement of the freedom of choice of the electorate by broadening the selection of would-be elective public officers. By rendering ineligible for public office those who have been elected and served for three consecutive terms in the same public elective post, the prohibition seeks to infuse new blood in the political arena.
x x x x
x x x [T]he new Third District where [Naval] was elected and has served is composed of the same municipalities comprising the previous Second District, absent the towns Gainza and [Milaor]. The territorial jurisdiction [Naval] seeks to serve for the term 2013-2016 is the same as the territorial jurisdiction he previously served. The electorate who voted for him in 2004, 2007 and 2010 is the same electorate who shall vote for him come May 13, 2013 Elections. They are the same group of voters who elected him into office for three consecutive terms.
The resolution of this Commission in the case of Bandillo, et al[.] v. Hernandez (SPA No. 10-078)13 cannot be applied in the case at bar. Hernandez who then hailed from Libmanan belonged to the First District of Camarines Sur. With Republic Act 9716, Libmanan, Minalabac, Pamplona, Pasacao and San Fernando, all originally belonging to the First District, were merged with Gainza and Milaor to form the Second District. With the addition of the municipalities of Gainza and Milaor, it cannot be said that the previous First District became the Second District only by name. The voters of Gainza and Milaor added to the electorate of the new Second District formed a different electorate, different from the one which voted for Hernandez in the 2001, 2004 and 2007 elections. In the case at bar, the municipalities comprising the new Third District are the same municipalities that consisted of the previous Second [District], absent Milaor and Gainza.
The Supreme Court, in Latasa v. [COMELEC], ruled that the conversion of the municipality into a city did not convert the office of the municipal mayor into a local government post different from the office of the city mayor[.]
x x x x14 (Citations omitted)
The conditions for the application of the three-term limit rule are present in the instant case as the records clearly establish that [Naval] is running for the 4th time for the same government post. To put things in a proper perspective, it is imperative to review and discuss the salient points in the case of Latasa v. [COMELEC]. The case involves the question of whether or not a municipal mayor, having been elected and had already served for three (3) consecutive terms, can run as city mayor in light of the conversion of the municipality to a city. In applying the three-term limit rule, the Court pointed out that the conversion of the municipality into a city did not convert the office of the municipal mayor into a local government post different from the office of the city mayor. The Court took into account the following circumstances: (1) That the territorial jurisdiction of [the] city was the same as that of the municipality; (2) That the inhabitants were the same group of voters who elected the municipal mayor for three (3) consecutive terms; and (3) That the inhabitants were the same group of voters [over] whom he held power and authority as their chief executive for nine years.
Anchoring from the said case, it is therefore clear that the position to which [Naval] has filed his candidacy for the 13 May 2013 x x x Elections is the same position for which he had been elected and had served for the past nine (9) years.
x x x x
x x x The following circumstances establish that the subject posts are one and the same: First, the territorial jurisdictions of the two (2) districts are the same except for the municipalities of Gainza and Milaor which were excluded by R.A. No. 9716; Second, the inhabitants of the 3rd District of Camarines Sur, where [Naval] is presently running as member of the [Sanggunian], are the same voters who elected him for the past three (3) consecutive terms; and Lastly, the inhabitants of the [3rd] District are the same group of voters whom [Naval] had served as member of the [Sanggunian] representing the 2nd District.
x x x The enactment of R.A. No. 9716 did not convert [Naval’s] post [into one] different from [w]hat he [previously had]. As correctly ruled by the Commission (Second Division), [Naval] ha[d] already been elected and ha[d] already served in the same government post for three consecutive terms, x x x[.]
x x x x.15 (Citations omitted)
- IN FINDING THAT NAVAL HAD ALREADY SERVED FOR THREE CONSECUTIVE TERMS IN THE SAME GOVERNMENT POST;16
- IN IGNORING THE FACT THAT SANGGUNIAN MEMBERS ARE ELECTED BY LEGISLATIVE DISTRICTS;17 and
- WHEN IT RULED THAT THE PROHIBITION CONTEMPLATED BY SECTION 8, ARTICLE X OF THE 1987 CONSTITUTION AND SECTION 43(B) OF THE LGC APPLIES TO NAVAL.18
A republic is a representative government, a government run by and for the people. It is not a pure democracy where the people govern themselves directly. The essence of republicanism is representation and renovation, the selection by the citizenry of a corps of public functionaries who derive their mandate from the people and act on their behalf, serving for a limited period only, after which they are replaced or retained, at the option of their principal. Obviously, a republican government is a responsible government whose officials hold and discharge their position as a public trust and shall, according to the Constitution, ‘at all times be accountable to the people’ they are sworn to serve. The purpose of a republican government it is almost needless to state, is the promotion of the common welfare according to the will of the people themselves.29 (Emphasis ours and italics in the original)
The electoral process is one of the linchpins of a democratic and republican framework because it is through the act of voting that government by consent is secured. Through the ballot, people express their will on the defining issues of the day and they are able to choose their leaders in accordance with the fundamental principle of representative democracy that the people should elect whom they please to govern them. Voting has an important instrumental value in preserving the viability of constitutional democracy. It has traditionally been taken as a prime indicator of democratic participation.31 (Citations omitted and italics ours)
True, election is the expression of the sovereign power of the people. In the exercise of suffrage, a free people expects to achieve the continuity of government and the perpetuation of its benefits. However, inspite of its importance, the privileges and rights arising from having been elected may be enlarged or restricted by law. x x x.32 (Italics ours)
VOTING ON THE TERMS OF LOCAL OFFICIALS
With respect to local officials, Mr. Nolledo, informed that the Committee on Local Governments had not decided on the term of office for local officials and suggested that the Body decide on the matter.
x x x x
On Mr. Bacani’s inquiry regarding local officials, Mr. Davide explained that local officials would include the governor, vice-governor and the members of the provincial board; the city mayor, city vice-mayor and members of the city board; and the municipal mayor, municipal vice mayor and members of the municipal council. He stated that barangay officials would be governed by special law, to which Mr. Nolledo agreed.
x x x x
MOTION TO VOTE ON THE PROPOSALS RELATIVE TO ALTERNATIVE NO. 3
In reply to Mr. Guingona’s query on whether the Committee had decided on the interpretation of “two reelections”, Mr. Davide suggested that the matter be submitted to a vote.
Thereupon, Mr. Romulo moved for a vote on whether Alternative No. 3 as proposed by Mr. Garcia, would allow a local official three terms, after which he would not be allowed to seek any reelection; or whether, as interpreted by Mr. Davide, it would mean that after two successive reelections or a consecutive period of nine years, he could run for reelection after the lapse of three years.
x x x x
RESTATEMENT OF THE PROPOSALS
Mr. Garcia reiterated that the local officials could be reelected twice, after which, they would be barred from ever running for reelection.
On the other proposal, Mr. Davide, on behalf of the Committee, stated that local officials after two reelections would be allowed to run for reelection after the lapse of three years.
x x x x
MANIFESTATION OF MR. ROMULO
Upon resumption of session, Mr. Romulo manifested that the Body would proceed to the consideration of two issues on the term of Representatives and local officials, namely: 1) Alternative No. 1 (no further reelection after a total of three terms), and 2) Alternative No. 2 (no immediate reelection after three successive terms).
SPONSORSHIP REMARKS OF MR. GARCIA ON ALTERNATIVE NO. 1
Mr. Garcia stated that he was advocating Alternative No. 1 on four grounds: 1) to prevent monopoly of political power because the country’s history showed that prolonged stay in public office could lead to the creation of entrenched preserves of political dynasties; 2) to broaden the choice so that more people could be enlisted to the cause of public service; 3) no one is indispensable in running the affairs of the country and that reliance on personalities would be avoided; and 4) the disqualification from running for reelection after three terms would create a reserve of statesmen both in the local and national levels.
He added that the turnover in public office after nine years would ensure the introduction of new ideas and approaches. He stressed that public office would no longer be a preserve of conservatism and tradition, and that public service would no longer be limited to those directly holding public office, but would also include consultative bodies organized by the people.
INQUIRY OF MR. REGALADO
In reply to Mr. Regalado’s query whether the three terms need not be served consecutively, Mr. Garcia answered in the affirmative.
SPONSORSHIP REMARKS OF MR. MONSOD ON ALTERNATIVE NO. 2
Mr. Monsod stated that while the new Constitution would recognize people power because of a new awareness, a new kind of voter and a new kind of Filipino, at the same time, it pre-screens the candidates among whom the people would choose by barring those who would have served for nine years from being reelected. He opined that this would actually require an additional qualification for office to a certain number of people.
He stressed that, while the stand of the Commission is to create a reserve of statesmen, their future participation is actually limited to some areas and only for a certain period of time. He added that it is not for the Commission to decide on the future of our countrymen who may have more years ahead of them to serve the country.
x x x x
INQUIRY OF MR. OPLE
x x x x
Thereupon, speaking in support of Mr. Monsod’s manifestation, Mr. Ople expressed apprehension over the Body’s exercise of some sort of omnipotent power in disqualifying those who will have served their tasks. He opined that the Commission had already taken steps to prevent the accumulation of powers and prequisites that would permit officials to stay on indefinitely and to transfer them to members of their families. He opined, however, that perpetual disqualification would deprive the people of their freedom of choice. He stated that the Body had already succeeded in striking a balance on policies which could ensure a redistribution of opportunities to the people both in terms of political and economic power. He stated that Philippine politics had been unshackled from the two-party system, which he said was the most critical support for the perpetuation of political dynasties. Considering that such achievement is already a victory, Mr. Ople stated that the role of political parties should not be despised because the strength of democracy depends on how strong political parties are, that a splintering thereof will mean a great loss to the vitality and resiliency of democracy.
Mr. Ople reiterated that he was against perpetual disqualification from office.
x x x x.
MR. GARCIA’S RESPONSE TO MR. OPLE’S STATEMENTS
Mr. Garcia stated that there are two principles involved in Alternative No. 1: 1 ) the recognition of the ambivalent nature of political power, and 2) the recognition of alternative forms of public service. He stated that it is important to remember the lessons learned from the recent past; that public service is service to the people and not an opportunity to accumulate political power, and that a prolonged stay in public office brings about political dynasties or vested interests. Regarding political parties, he stated that it will encourage the constant renewal of blood in party leadership, approach, style and ideas. He opined that this is very healthy for a pluralist and multi-party democracy.
On the recognition of alternative forms of public service, Mr. Garcia stressed that public service could be limited to public office since many good leaders who were in the streets and in jail fought against the dictatorship. He stressed that public service would also mean belonging to consultative bodies or people’s councils which brought about new forms of service and leadership.
REMARKS OF MR. ABUBAKAR
Mr. Abubakar stated that in any democracy the voice of the people is the voice of God. He stated that if the people want to elect a representative to serve them continuously, the Commission should not arrogate unto itself the right to decide what the people want. He stated that in the United States, a Senator had served for 30 years.
x x x x
REMARKS OF MS. AQUINO
Ms. Aquino stated that she differs from the views advanced by Mr. Garcia and Ms. Tan, although she stated that they spoke of the same premises. She stated that she agrees with them that leaders need not be projected and developed publicly in an election as leaders are better tempered and tested in the various forms of mass struggles and organized work. She stated that if the people are to be encouraged to have their own sense of responsibility in national leadership, what ultimately matters is the political determination of the citizenry to chart their own national destiny. She opined that the Body should allow the people to exercise their own sense of proportion and imbibe the salutary effects of their own strength to curtail power when it overreaches itself. She stressed that in the final analysis, the Commission cannot legislate into the Constitution the essence of new politics as it is a chastening experience of learning and unlearning. Adverting to Mr. Garcia’s statement that politics is an imperfect art, she stated that the Commission could correct politics with all its imperfections and flaws by a constitutional provision. She opined that perpetual disqualification cannot provide the cure. She maintained that perpetual disqualification is, at best, a palliative which could also be counter-productive, in the sense that it could effectively foil the possibilities of real public service.
REMARKS OF MR. BACANI
Mr. Bacani stated that when the Body granted the illiterates the right to vote and that proposals were made to empower the people to engage in the legislative process, the Body presupposed the political maturity of the people. He observed that in this instance, political maturity is denied with the constitutional bar for reelection. He opined that the Body should stick to the premise that the people are politically mature.
REJOINDER OF MR. GARCIA
By way of rejoinder to Mr. Bacani’s statements, Mr. Garcia stated that the proposal was basically premised on the undue advantage of the incumbent in accumulating power, money, party machine and patronage and not on lack of trust in the people.
Mr. Garcia stated that politics is not won by ideals alone but by solid organized work by organizations. He stated that with three terms, an official would have served the people long enough.
x x x x
VOTING ON THE TWO ALTERNATIVES
Thereafter, the Body proceeded to vote by ballot on the two alternatives.
x x x x
RESULT OF THE VOTING
The result of the voting was as follows:
Alternative No. 1 (no further election after three successive terms) — 17 votes
Alternative No. 2 (no immediate reelection after three successive terms) — 26 votes
With 17 votes in favor of Alternative No. 1 and 26 in favor of Alternative No. 2, the Chair declared Alternative No. 2 approved by the Body.36 (Emphasis and italics ours)
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.
Significantly, this provision refers to a “term” as a period of time – three years – during which an official has title to office and can serve. x x x[.]
x x x x
The “limitation” under this first branch of the provision is expressed in the negative—“no such official shall serve for more than three consecutive terms.” This formulation—no more than three consecutive terms—is a clear command suggesting the existence of an inflexible rule. x x x.
x x x x
This examination of the wording of the constitutional provision and of the circumstances surrounding its formulation impresses upon us the clear intent to make term limitation a high priority constitutional objective whose terms must be strictly construed and which cannot be defeated by, nor sacrificed for, values of less than equal constitutional worth. x x x.
x x x x
x x x [T]he Court signalled how zealously it guards the three-term limit rule. Effectively, these cases teach us to strictly interpret the term limitation rule in favor of limitation rather than its exception.
x x x x
[In] Latasa v. Commission on Elections x x x[,] [t]he Court said:This Court reiterates that the framers of the Constitution specifically included an exception to the people’s freedom to choose those who will govern them in order to avoid the evil of a single person accumulating excessive power over a particular territorial jurisdiction as a result of a prolonged stay in the same office. x x x.x x x x
To put it differently although at the risk of repetition, Section 8, Article X—both by structure and substance—fixes an elective official’s term of office and limits his stay in office to three consecutive terms as an inflexible rule that is stressed, no less, by citing voluntary renunciation as an example of a circumvention. x x x.39 (Citations omitted, italics and emphasis in the original and underscoring ours)
Section 1. The composition of the current First (1st) and Second (2nd) Legislative Districts in the Province of Camarines Sur is hereby reapportioned in order to create an additional legislative district to commence in the next national elections after the effectivity of this Act.
Section 2. In furtherance of the reapportionment mandated by this Act, the municipalities of Libmanan, Minalabac, Pamplona, Pasacao and San Fernando of the current First (1st) Legislative District are hereby consolidated with the municipalities of Gainza and Milaor of the current Second (2nd) Legislative District, to comprise the new legislative district authorized under this Act.
Section 3. The result of the reapportionment described in this Act are summarized as follows:
a) First District – The remaining municipalities in the current First (1st) Legislative District shall continue to be designated as the First (1st) Legislative District, composed of the following municipalities: Del Gallego, Ragay, Lupi, Sipicot and Cabusao; b) Second District – This new legislative district shall be composed of the municipalities enumerated in Section 2 hereof; c) Third District – The current Second (2nd) Legislative District shall be renamed as the Third (3rd) Legislative District, composed of the following: Naga City and the municipalities of Pili, Ocampo, Camaligan, Canaman, Magarao, Bombon and Calabanga; d) Fourth District – The current Third (3rd) Legislative District, without any change in its composition, shall be renamed as the Fourth (4th) Legislative District, composed of the following municipalities: Caramoan, Garchitorena, Goa, Lagonoy, Presentacion, Sangay, San Jose, Tigaon, Tinambac and Siruma; and e) Fifth District – The current Fourth (4th) Legislative District, without any change in its composition, shall be renamed as the Fifth (5th) Legislative District, composed of the following: Iriga City and the municipalities of Baao, Balatan, Bato, Buhi, Bula and Nabua. (Italics and emphasis ours)
R.A. No. 9716 created a new Second
Before the Enactment of
After the Enactment of
First, the general rule in construing words and phrases used in a statute is that, in the absence of legislative intent to the contrary, they should be given their plain, ordinary and common usage meaning; the words should be read and considered in their natural, ordinary, commonly accepted usage, and without resorting to forced or subtle construction. Words are presumed to have been employed by the lawmaker in their ordinary and common use and acceptation.
Second, a word of general significance in a statute is to be taken in its ordinary and comprehensive sense, unless it is shown that the word is intended to be given a different or restricted meaning; what is generally spoken shall be generally understood and general words shall be understood in a general sense.44 (Citations omitted)
1Rollo, pp. 3-22; Please also see Amended Petition, id. at 126-145.
2 Id. at 25-35.
3 Id. at 62.
4 Sec. 8. The term of office of elective local officials, except barangay officials, which shall be determined by law, shall be three years and no such official shall serve for more than three consecutive terms. Voluntary renunciation of the office for any length of time shall not be considered as an interruption in the continuity of his service for the full term for which he was elected.
5 Sec. 43. Term of office. – x x x
x x x x
(b) No local elective official shall serve for more than three (3) consecutive terms in the same position. Voluntary renunciation of the office for any length of time shall not be considered as an interruption in the continuity of service for the full term for which the elective official concerned was elected.
6Rollo, pp. 37-45.
7 Id. at 115-124.
8 AN ACT REAPPORTIONING THE COMPOSITION OF THE FIRST (1ST) AND SECOND (2ND) LEGISLATIVE DISTRICTS IN THE PROVINCE OF CAMARINES SUR AND THEREBY CREATING A NEW LEGISLATIVE DISTRICT FROM SUCH REAPPORTIONMENT.
9 Naval is a resident of Calabanga.
10 Sec. 78. Petition to deny due course to or cancel a certificate of candidacy. – A verified petition seeking to deny due course or to cancel a certificate of candidacy may be filed by any person exclusively on the ground that any material representation contained therein as required under Section 74 hereof is false. The petition may be filed at any time not later than twenty-five days from the time of the filing of the certificate of candidacy and shall be decided, after due notice and hearing, not later than fifteen days before the election.
11Rollo, pp. 46-59.
12 Id. at 56-57, citing Aldovino, Jr. v. COMELEC, G.R. No. 184836, December 23, 2009, 609 SCRA 234.
13 Please see COMELEC Resolutions dated May 8, 2010 (id. at 79-83) and January 31, 2011 (id. at 84-88.) disposing of this case.
14 Id. at 28-34.
15 Id. at 42-44.
16 Id. at 132.
17 Id. at 135.
18 Id. at 137.
19 Art. 94. Manner of Election and Number of Elective Sanggunian Members. – (a) Sangguniang panlalawigan –
(1) For provinces with two (2) or more legislative districts, the elective members of the sangguniang panlalawigan shall be elected by legislative districts. For this purpose, they shall be apportioned equitably provided that if equal division is not possible, the remaining member or members shall be elected in the district or districts with the greater number of population or, if they be the same, with the greater number of voters; and provided further, that if a legislative district comprises an independent component city such that an equal distribution of sanggunian members does not result in equitable apportionment on the basis of population of the province, the Comelec shall allocate the number among the districts in proportion to the population or constituencies voting for the members of the sangguniang panlalawigan.
(2) For provinces with only one (1) representative district, the Comelec shall divide the members into two (2) districts for purposes of provincial representation as nearly as practicable according to the number of inhabitants. Each district comprising a compact, contiguous and adjacent territory, and the number of elective members of their respective sanggunians shall be equitably apportioned between the districts in accordance with the standard or formula provided in the immediately preceding subparagraph (1).
(3) First and second class provinces shall each have ten (10) elective members; third and fourth class provinces, eight (8); and fifth and sixth class provinces, six (6) to be elected at large by the qualified voters therein.
20 356 Phil. 467 (1998).
21 Id. at 478.
22 463 Phil. 296 (2003).
23 Supra note 13.
24 Please see Reply, id. at 288-289.
25 Id. at 263-279.
26 370 Phil. 625 (1999).
27 G.R. No. 184836, December 23, 2009, 609 SCRA 234.
28 1987 Constitution, Article II, Section 1.
29Concurring Opinion in Frivaldo v. COMELEC, 327 Phil. 521, 579 (1996), citing Cruz, Philippine Political Law, p. 49, [1991 ed].
30 465 Phil. 385 (2004).
31 Dissenting Opinion of then Associate Justice Reynato S. Puno, id. at 433.
32People v. Jalosjos, 381 Phil. 690, 700 (2000).
33 Please see Yason v. COMELEC, 219 Phil. 338 (1985).
34 Please see 1987 Constitution, Article II, Section 26.
35 Please see COMELEC v. Cruz, G.R. No. 186616, November 20, 2009, 605 SCRA 167, 191, citing Montesclaros v. COMELEC, 433 Phil. 620, 637 (2002).
36 I Journal, Constitutional Commission (July 25, 1986).
37 The words of the Constitution should be construed in accordance with the intent of its framers.
38Francisco, Jr. v. The House of Representatives, 460 Phil. 830, 885-886 (2003), citing Civil Liberties Union v. Executive Secretary, G.R. No. 83896, February 22, 1991, 194 SCRA 317, 325.
39 Supra note 27, at 250-261.
40Bagabuyo v. COMELEC, 593 Phil. 678, 690-691 (2008), citing Black’s Law Dictionary, 5th Edition, p. 1137.
41 Id. at 690, citing Clapp, James E., Dictionary of Law (2000), p. 33.
42 Id. at 701.
43 Please see Aquino III v. COMELEC, G.R. No. 189793, April 7, 2010, 617 SCRA 623, 631-632.
44 Concurring Opinion of Associate Justice Arturo D. Brion in Orceo v. COMELEC, G.R. No. 190779, March 26, 2010, 616 SCRA 684, 703.
45 Supra note 37.
47 (visited June 19, 2014).
48 (visited June 19, 2014).
49 Supra note 40.
50Typoco v. COMELEC, G.R. No. 186359, March 5, 2010, 614 SCRA 391, 405-406.
51 Id. at 400.
53 (visited June 19, 2014).
54 Bens Storybook, Odysseus and the Sirens, (visited June 19, 2014).