G.R. No L-45081 Angara v.

Electoral Commission
Petitioner: Jose A. Angara
Respondents: Electoral Commission, Pedro Ynsua, Miguel Castillo, Dionisio C. Mayor
Ponente: J. Laurel
Facts:
1. Petitioner Jose Angara was proclaimed winner and took his oath of office as member of the
National Assembly of the Commonwealth Government.
2. On December 3, 1935, the National Assembly passed a resolution confirming the election of
those who have not been subject of an election protest prior to the adoption of the said
resolution.
3. On December 8, 1935, however, private respondent Pedro Ynsua filed an election protest
against the petitioner before the Electoral Commission of the National Assembly. The following
day, December 9, 1935, the Electoral Commission adopted its own resolution providing that it
will not consider any election protest that was not submitted on or before December 9, 1935.
4. Citing the resolution of the National Assembly, the petitioner sought the dismissal of
respondents protest. The Electoral Commission however denied his motion.
Doctrine:
The Senate and the House of Representatives shall each have an Electoral Tribunal, which shall be
the sole judge of all contests relating to the election, returns, and qualifications of their respective
Members.
Issue:
W.O.N. the Electoral Commission acted without or in excess of its jurisdiction in taking cognizance of
the protest filed against the election of the petitioner notwithstanding the previous confirmation of
such election by resolution of the National Assembly
Held/Ratio Decidendi:
No. The Electoral Commission did not act without or in excess of its jurisdiction in acknowledging the
protest filed against the election of the petitioner in spite of the resolution of the National Assembly.
The Electoral Commission acted within the legitimate exercise of its constitutional prerogative in
assuming to take recognition of the protest filed by the respondent Ynsua against the election of the
petitioner Angara, and that the earlier resolution of the National Assembly cannot in any manner toll
the time for filing election protests against members of the National Assembly, nor prevent the filing of
a protest within such time as the rules of the Electoral Commission might prescribe.
The Electoral Commission, being the sole judge of all contests relating to the election, returns and
qualifications of members of the National Assembly, is an independent constitutional creation with
specific powers and functions to execute and perform, closer for purposes of classification to the
legislative than to any of the other two departments of the government.
The grant of power to the Electoral Commission 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. The express lodging of that power in the
Electoral Commission is an implied denial of the exercise of that power by the National Assembly.
Petition denied.