A recall can be initiated by a petition of at least 25% of the registered voters in the local government unit (LGU) concerned.

[4] Garcia sued for relief in the Supreme Court, which granted his petition on September 21 for lack of due process.

Two days later, Mariveles mayor Oscar de los Reyes moved to recall Garcia again.

The PRA reconvened in the Balanga town plaza, was attended by pro-Garcia politicians, who walked out of the proceedings.

[3] By November, the COMELEC asked the government 6.4 million pesos for the conduct of the recall election, and it was expecting one or two candidates to challenge Garcia.

The COMELEC, on criticism that it scheduled the election during the Christmas season, countered that it will be more expensive to hold it on the following year.

[15] People from Bataan expressed disappointment with the delay of the proclamation, as Garcia protested the inclusion of 99 election returns from Dinalupihan.

[20] A day later, the Supreme Court dismissed Roman's petition to lift the restraining order on the proclamation of the winner.

[21] On June 17, 1994. the COMELEC en banc reaffirmed its dismissal of Garcia's petition regarding the leaflets dropped on polling day; notably, chairman Christian Monsod was the sole dissenting vote.

[22] On the next day, the Supreme Court dismissed the petition of Garcia suspending Roman's proclamation as the winner.

[26] In 2004, Garcia won the governorship, as his son Albert defeated Roman for congressman from Bataan's 2nd district.

[27] Garcia was reelected in 2007 and 2010, returned to Congress in 2013, and was elected as vice governor in 2016 when he died prior to taking office.