Title
Elroy John M. Hagedorn vs House of Representatives of the Philippines
Case
G.R. No. 275800
Decision Date
Apr 22, 2025
SC clarifies COMELEC's duty to call special elections for House vacancies; no House resolution needed.

Case Digest (G.R. No. 275800)

Facts:

Elroy John M. Hagedorn v. House of Representatives of the Philippines, G.R. No. 275800, April 22, 2025, Supreme Court En Banc, Hernando, J., writing for the Court.

Petitioner Elroy John M. Hagedorn filed a Petition for Mandamus asking the Court to compel the House of Representatives, through Speaker Ferdinand Martin G. Romualdez, Secretary General Reginald S. Velasco, and Chairperson Maximo Y. Dalog, Jr., to adopt a resolution certifying a permanent vacancy in the Third Legislative District of Palawan and calling on the Commission on Elections (COMELEC) to hold a special election to fill that vacancy.

The vacancy arose when Representative Edward S. Hagedorn (elected May 2022) died on October 3, 2023. Local government bodies and constituents sent resolutions and letters requesting that the House certify the vacancy and call for a special election; the House designated Speaker Romualdez as legislative caretaker on November 8, 2023. On March 20, 2024 Representative Eduardo Villanueva filed House Resolution No. 1661 to certify the vacancy and request COMELEC to hold a special election; as of the petition the resolution remained pending with the Committee on Suffrage and Electoral Reforms. Petitioner sent letters to the Speaker and to COMELEC (including submissions of constituent signatures), but COMELEC repeatedly replied that, under Republic Act No. 6645, it requires a resolution from the relevant chamber certifying the vacancy before it may hold a special election. Petitioner then filed the present Pe...(Pro-only)

Issues:

  • Is the Court’s exercise of judicial review warranted (i.e., are the issues justiciable given mootness, standing, and the propriety of direct recourse)?
  • May the House of Representatives be compelled by a writ of mandamus to issue a resolution certifying the existence of a vacancy in the House of Representatives and calli...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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