up by a special election. Commonwealth Congress No special elections were called for the Commonwealth Congress. Starting from 1941, senators elected at-large nationwide, have 6-year terms, with senators elected via staggered elections: every two years, eight out of the 24 senators were elected from 1940 to 1972, and 12 out of 24 senators every three years since 1987. In cases where a senator left office before the expiration of his term, a special election on the day of the next regularly scheduled Senate election was held to fill up the vacancy, as long as the seat per se won't be contested on that election day. There had been three cases where that happened. Congress Statistics Death and leaving office for another position are the most frequent reasons why there are senatorial special elections: Per election 1951 In 1949, Senator Fernando Lopez (who was on his second year of service in the Senate) was elected Vice President of the Philippines. To fill the vacancy, a special election was held separately with senators whose terms ended in that year: 1955 In 1953, Senator Carlos P. Garcia (who was on his second year of service in the Senate) was elected Vice President of the Philippines. To fill the vacancy, a special election was held separately with senators whose terms ended in that year: 2001 In 2001, Vice President Gloria Macapagal Arroyo succeeded Joseph Estrada after the 2001 EDSA Revolution, leaving the office of the vice president vacant. Arroyo appointed Teofisto Guingona (who was serving the second year of his second term as senator) as vice president later that year but prior to the 2001 Senate election. The Commission on Elections ruled that instead of twelve, the electorate will vote for thirteen senators, with the thirteenth-placed candidate serving Guingona's unexpired term of three years. For purposes of term limits, that senator was deemed to have served a full six-year term. Former senator Arturo Tolentino and others sued the Commission on Elections (Comelec) to set aside the proclamation of the thirteen senators in 2001. In Tolentino vs. Comelec, the Supreme Court ruled that the commission did not comply with the requirements of R.A. 6645, nor did the commission "give formal notice that it would proclaim as winner the senatorial candidate receiving the 13th highest number of votes in the special election." However, the court ruled that while the commission failed to give notice of the