Republic Act No. 9716 separated eight out of its ten towns comprising a
legislative district and renamed them as another district. Thereafter, a provincial board member was elected
to the same position for the third and fourth time, but now in representation
of the renamed district. The Supreme Court in Naval v. Commission on Elections held that the fourth election was a violation of the three-term limit
rule because the renamed district is the same one which brought him to office. The
Supreme Court added that the actual difference in the population of the old Second
District from that of the current Third District amounts to less than 10% of
the population of the latter. This fact renders “the new Third District as
essentially, although not literally, the same as the old Second District.”
 Naval v. Commission on Elections, G.R. No.
207851, July 8, 2014.