# 1994 Rizal's 1st congressional district special election

A special election was held for Rizal's 1st district seat to the House of Representatives of the Philippines on March 7, 1994. Gilberto Duavit Sr. won the special election to serve the final 14 months of former representative Manuel Sanchez's term.
This was the first competitive special election held under the auspices of the 1987 constitution; the special elections in 1993 were all uncontested.

## Background

Incumbent representative Manuel Sanchez was removed from office after the House of Representatives Electoral Tribunal ruled that he is an American citizen. A special election was then called, scheduled for March 7, 1994. Six candidates participated including Rogelio Sanchez Silvestre, Sanchez's nephew, former House majority leader Francisco Sumulong, former assemblyman Gilberto Duavit Sr. of the opposition Nationalist People's Coalition (NPC), and three independent candidates: chess grandmaster Rosendo Balinas Jr., lawyer Eduardo Inlayo and peasant leader Elmer Panotes.
Sumulong previously served as representative but gave up his seat to run unsuccessfully in the 1992 Senate election. Sumulong was supported by presidents Corazon Aquino and Fidel Ramos. Duavit was supported by Rizal governor Casimiro Ynares and vice president Joseph Estrada, while Silvestre was backed by former Senate President Jovito Salonga and other Liberal Party stalwarts.
Cainta and Taytay were expected to provide the swing votes as none of the candidates are from those two municipalities, and that many residents there were immigrants from other parts of the country. Turnout was expected to be low as no holiday was declared on election day.

## Campaign

A seventh candidate, Joey Mendoza from Binangonan, withdrew and supported Sumulong. The special election was seen as a proxy war between Sumulong and Duavit on who the masses support between President Ramos and Vice President Estrada. The Silvestre and Duavit camps allege that Sumulong, when he was a congressman, hardly produced anything that benefitted Rizal. Sanchez had to fight off efforts of disallowing his maternal name "Sanchez" from being used, securing a Supreme Court temporary restraining order allowing him to include that on the ballot.
The Commission on Elections instructed candidates to remove illegally-posted campaign materials or be disqualified.

## Result

1994 Rizal's 1st congressional district special election :
| Candidate | Candidate | Party | Votes | % |
| | Gilberto Duavit Sr. | Nationalist People's Coalition | 59,987 | 46.46 |
| | Francisco Sumulong | Lakas–NUCD | 38,953 | 30.17 |
| | Rogelio Sanchez Silvestre | Liberal Party | 29,035 | 22.49 |
| | Eduardo Inlayo | Independent | 729 | 0.56 |
| | Rosendo Balinas Jr. | Independent | 270 | 0.21 |
| | Elmer Panotes | Independent | 144 | 0.11 |
| Total | Total | Total | 129,118 | 100.00 |
| Valid votes | Valid votes | Valid votes | 129,118 | 99.10 |
| Invalid/blank votes | Invalid/blank votes | Invalid/blank votes | 1,174 | 0.90 |
| Total votes | Total votes | Total votes | 130,292 | 100.00 |
| Registered voters/turnout | Registered voters/turnout | Registered voters/turnout | 349,584 | 37.27 |
| Majority | Majority | Majority | 21,034 | 16.29 |
| | Nationalist People's Coalition gain from Lakas–NUCD | Nationalist People's Coalition gain from Lakas–NUCD | Nationalist People's Coalition gain from Lakas–NUCD | Nationalist People's Coalition gain from Lakas–NUCD |
Duavit won over former representative Francisco Sumulong by 21,034 votes. The low turnout of 37% was blamed on Rizal's traffic problems, and the inability of employees and students to cast their votes when they reside outside the district during the workweek/school week.
After his election victory, a member of the Duavit family has served as representative of Rizal's 1st district up to the current 19th Congress.