TERM PERIODS OF THE

HEADS OF
CONSTITUTIONAL
COMMISSIONS
First Batch of Appointees

 Chairman – 7 years
 Commissioner 1 – 5 years
 Commissioner 2 – 3 years
 Their term will start on FEBRUARY 2, 1987, the date the 1987 Constitution
took effect
 Purpose: To maintain the two-year interval between the expiration of terms
thereafter
 The second and succeeding batches of appointees will have regular terms of 7
years each.
Gaminde vs COA:

 Thelma Gaminde was appointed as Commissioner of CSC for a term expiring

on February 2, 1999;
 She assumed office on June 22, 1993;
 She sought clarification from the Chief Presidential Legal Counsel, who told
her that her term will expire on February 2, 2000;
 Thus, she remained in office even after February 2, 1999;
 COA disallowed her salary and the salaries of her co-terminous staff effective
February 2, 1990
 ISSUE: Whether her term expired on February 2, 1999 as stated in her
appointment paper, or on February 2, 2000 as claimed by her
Court’s Ruling

 Her term expired on February 2, 1999.

 Sec. 1, par. 2, of Art. IX (B) of the 1987 Constitution states: The Chairman and the
Commissioners shall be appointed by the President with the consent of the
Commission on Appointments for a term of seven years without reappointment. Of
those first appointed, the Chairman shall hold office for seven years, a
commissioner for five years, and another commissioner for three years, without
reappointment. Appointment to any vacancy shall be only for the unexpired term of
the predecessor. In no case shall any member be appointed or designated in a
temporary or acting capacity.
 The terms of the first Chairman and Commissioners of the Constitutional
Commissions under the 1987 Constitution must start on a common date, February 2,
1987 (the date the 1987 Constitution took effect), irrespective of their date of
actual assumption of office, in order that the expiration of the first terms of 7-5-3
years will lead to the regular recurrence of the two-year interval between the
expiration of the terms.
First Batch of Appointees
 CHAIRMAN: Patricia Sto. Tomas
 Term: 7 years
 Period: February 2, 1987 to February 2, 1994
 Date of actual assumption of office: March 4, 1988
 Regardless of date of assumption, her term will end on February 2, 1994
 COMMISSIONER 1: Samilo N. Burlongay
 Term: 5 years
 Period: February 2, 1987 to February 2, 1992
 Date of actual assumption of office: March 4, 1988
 Regardless of date of assumption, term will end on February 2, 1992
 COMMISSIONER 2: Mario D. Yango
 Term: 3 years
 Period: February 2, 1987 to February 2, 1990
 Date of actual assumption: May 30, 1988
 Regardless of date of assumption, term will end February 2, 1990
Second Batch of Appointees
 CHAIRMAN: Corazon Alma de Leon
 Term: 7 years
 Period: February 2, 1994 to February 2, 2001
 Date of actual assumption of office: March 22, 1995
 Regardless of date of assumption, her term will end on February 2, 2001
 COMMISSIONER 1: Thelma Gaminde
 Term: 7 years
 Period: February 2, 1992 to February 2, 1999
 Date of actual assumption of office: June 22, 1993
 Regardless of date of assumption, term will end on February 2, 1999
 COMMISSIONER 2: Ramon Ereñeta
 Term: 7 years
 Period: February 2, 1990 to February 2, 1997
 Date of actual assumption: December 12, 1991
 Regardless of date of assumption, term will end February 2, 1997
Regular interval of vacancy every two
years, namely:
 February 2, 1994– 1st Chairman
 February 2, 1992– 1st Commissioner 1 (5-year term)
 February 2, 1990– 1st Commissioner 2 (3-year term)

 Their successors must also maintain the 2-year interval, namely:

 February 2, 2001– 2nd Chairman
 February 2, 1999– 2nd Commissioner 1
 February 2, 1997– 2nd Commissioner 2
Third Batch of Appointees’ terms of
office:
 Chairman: February 2, 2001 to February 2, 2008 – 7 years
 Commissioner 1: February 2, 1999 to February 2, 2006 – 7 years
 Commissioner 1: February 2, 1997 to February 2, 2004 – 7 years
Note: This rule applies to all three
commissions.