Second Lady of the United States fell out of favor, but was revived in the 1980s. During the 1990s the title was again abandoned, in favor of "wife of the Vice President", but was later resurrected during the administration of Barack Obama. Its use was continued by the administration of Donald Trump, although Donald Trump himself said, during his presidency, that he had never heard the term. Fourteen Second Ladies have gone on to become First Lady of the United States during their husband's terms as President. The first to do this was Abigail Adams, who was married to John Adams, who was the first Vice
President of the Philippines reelection and a person who has succeeded as President and has served as such for more than four years will be ineligible to be elected for a second term. However, with the case of Joseph Estrada who was elected president in 1998, deposed in 2001, and again ran for the presidency in 2010, the Constitution's wording where "[the] President shall not be eligible for any re-election" remains unclear as his case was never brought to the Supreme Court. It remains unclear whether the term limit of no re-election applies only to the incumbent President or for any person who has