Angara vs Electoral Commission
July 15, 1936 | Ponente Abad, J.
Topic: Judicial Review
Doctrine: The Electoral Commission, an independent organ, is granted power by the
Constitution to judge all contests relating to the election, returns and qualifications
of members of the National Assembly, is intended to be as complete and unimpaired
as if it had remained originally in the Legislature.
Facts:
1. The petition is an original action instituted in the Supreme Court by
petitioner Jose Angara for the issuance of a writ of prohibition to restrain and
prohibit the respondent Electoral Commission from taking further
cognizance of the protest filed by another respondent Pedro Ynsua, against
the election of Angara as a member of the National Assembly for the first
assembly district of the Province of Tayabas.
2. [September 17, 1935] Angara, Ynsua, Castillo, and Dionisio Mayor were
candidates for the position of member of the National Assembly for the first
district of the Province of Tayabas.
3. [October 7, 1935] Angara was proclaimed by the provincial board of
canvassers as member-elect of the National Assembly for receiving the most
number of votes.
4. [November 15, 1935] Angara took his oath of office.
5. [December 3, 1935] The National Assembly passes Resolution No. 8, which
approved and confirmed each and every deputy whose election was not
protested before the passing of said resolution.
6. [December 8, 1935] Ynsua filed a “Motion of Protest” contesting that he
should have won.
7. [December 9, 1935] The Electoral Commission adopted a resolution, wherein
paragraph 6 stated that, “The Commission will not consider any protest that
has not been filed on or before this date.”
8. [December 20, 1935] Angara filed a petition of “Motion to Dismiss the
Protest.”
9. [December 27, 1935] Ynsua filed an “Answer to the Motion of Dismissal.”
10. [December 31, 1935] Angara filed a “Reply.”
11. [January 23, 1936] The Electoral Commission denied the “Motion to Dismiss
the Protest.”
Issues:
1. W/N the Supreme Court has jurisdiction over the Electoral Commission and
the subject matter of the controversy upon the foregoing related facts.
2. W/N said Electoral Commission acted without or in excess of its jurisdiction
in assuming to take cognizance of the protest filed against the election of the
herein petitioner notwithstanding the previous confirmation of such election
by resolution of the National Assembly.
Ruling:
1. Upon principle, reason, and authority, the Court finds that it has
jurisdiction over the Electoral Commission and the subject matter of the
present controversy for the purpose of determining the character, scope,
and extent of the constitutional grant of the Electoral Commission as “the
sole judge of all contests relating to the election, returns and
qualifications of the members of the National Assembly.
In cases of conflict, the judiciary is the constitutional organ that can be
called upon to determine the proper allocation of powers among the
departments created by the Constitution.
2. In this case, the Electoral Commission was acting within the legitimate
exercise of its constitutional prerogative in taking cognizance of the
protest filed by Pedro Ynsua against the election of Jose A. Angara, and
that Resolution No. 8 of the National Assembly cannot determine the time
for filing protests against the election, returns and qualifications of
members of the National Assembly, nor prevent the filing of a protest
witin such time as the rules of the Electoral Commission might prescribe.
The avowed purpose in creating the Electoral Commission was to have an
independent constitutional organ with regard to dealing with all contests
relating to the election, returns and qualifications of members of the
National Assembly, devoid of partisan influence and consideration, which
object would be frustrated if the National Assembly were to retain the
power to prescribe rules and regulations regarding the manner of
conducting said contests.
Petition for writ of prohibition against the Electoral Commission is denied, with
costs against the petitioner.
Separate Opinion:
Abad Santos, J:
Concurred with the ruling, however pointed out that the powers of
the Electoral Commission are both judicial and legislative in nature (to judge and to
determine the rules in judging said contests).
