Twenty-second Amendment to the United States Constitution
Some argue that the 22nd Amendment and 12th Amendment bar any two-term president from later serving as vice president as well as from succeeding to the presidency from any point in the presidential line of succession. Others contend that the original intent of the 12th Amendment concerns qualification for "service" (age, residence, and citizenship), while the 22nd Amendment, concerns qualifications for "election", and thus (strictly applying the text) a former two-term president is still eligible to "serve" as vice president (neither amendment restricts the number of times an individual can be elected to the vice presidency), and then succeed to the presidency to serve out the balance of the term (though prohibited from running for election to an additional term).
Manuel L. Quezon
Coincident with the local elections for the 1940, another plebiscite was held this time to ratify the proposed amendments to the Constitution regarding the restoration of the bicameral legislature, the presidential term, which was to be fixed at four years with one re-election; and the establishment of an independent Commission on Elections. With the Nacionalista Party, which had proposed said amendment in their convention, working hard under the leadership of its party president, Speaker Jose Yulo, the amendments were overwhelmingly ratified by the electorate. Speaker Yulo and Assemblyman Dominador Tan traveled to the United States to obtain President Franklin D. Roosevelt's approval, which was given on December 2, 1940. Two days later President Quezon proclaimed the amendments.