Angara V Electoral Commission
Angara V Electoral Commission
Angara V Electoral Commission
Electoral Commission
63 Phil. 134
G.R No. L-45081, July 15, 1936
Facts:
Jose A. Angara and the respondents Pedro Ynsua, Miguel Castillo and Dionisio Mayor, were
candidates voted for the positon of member of the National Assembly of the Province of Tayabas.
Angara won the most number of votes and took his oath of office. The National Assembly on
December 3, 1935 submitted Resolution No. 8 which declared with finality the victory of Angara. On
December 8, Ynsua filed before the National Assembly a motion protesting against the election of
Angara and that he should be declared as a winner or the election for the positon be nullified. The
Electoral Commission adopted a resolution on Dec. 9 as the last day of filing of election protest. The
petitioner then filed before the Electoral Commission a motion to dismiss the protest that the
objection against him was filed out of the prescribed period. Angara contented that the Constitution
confers exclusive jurisdiction upon the Electoral Commission as regards to the merits of contested
elections to the National Assembly.
Issue:
Whether or not the Supreme Court has jurisdiction over the Electoral Commission and the subject
matter of the controversy
Whether or not the Electoral Commission has acted without or in excess of its jurisdiction in
assuming the cognizance of the protest filed the election of the herein petitioner notwithstanding the
previous confirmation of such election by resolution of the National Assembly.
Ruling:
Yes, the Supreme Court 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 to 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 between several departments and among agencies thereof, the judiciary, with the
Supreme Court as the final arbiter, is the only constitutional mechanism devised finally to resolve the
conflict and allocate constitutional boundaries.
No, the Electoral the Commission was acting within the legitimate exercise of its constitutional
prerogative in assuming to take cognizance of the protest filed by the respondent Pedro Ynsua
against the election of the petitioner Jose A. Angara, and that the resolution of the National
Assembly of December 3, 1935 cannot in any manner toll the time for filing protests against the
elections, returns and qualifications of members of the National Assembly, nor prevent the filing
protest within such time as the rules of the Electoral Commission might prescribe.