Angara vs. Electoral Commission, 63 Phil.

139

July 15, 1936

Petitioner: A. Angara
Respondents: The Electoral Commission, Pedro Ynsua, Miguel Castillo, and Dionisio C. Mayor
THEORY AND JUSTIFICATION OF JUDICIAL REVIEW
Facts:

October 7, 1935 Petitioner proclaimed to have won the position as Member of the
National Assembly for the First Assembly District of the province of Tayabas. On
November 15, he took his oath of office.
December 3, 1935 The National Assembly, through Resolution No.8, confirmed the
election of Petitioner.
December 8, 1835 Respondent (and failed candidate) Pedro Ynsua filed a Motion of
Protest before the Electoral Commission against the election of Petitioner.
December 20, 1935 Petitioner filed a Motion to Dismiss the Protest, alleging that his
position has already been confirmed by the National Assembly. The Electoral
Commission denied his petition.
Petitioner applied for Writ of Prohibition of the EC to take further cognizance of Ynsuas
protest, on the grounds that the Legislative has the primary power to regulate proceedings
with regards to contested elections, and consequently, that the EC should respect and
obey Resolution no.8.

Issues:

WoN the Supreme Court has jurisdiction over the Electoral Commission and the subject
matter of Controversy
WoN the Electoral Commission acted in excess of its jurisdiction in taking into
cognizance the protest of Ynsua notwithstanding the resolution of the National Assembly

Held:

Yes; The Judiciary, with the Supreme Court as the final arbiter, is the only constitutional
mechanism devised to resolve conflicts and to allocate constitutional boundaries. Judicial
Review is the means by which the Judiciary is able to check and balance the other
branches of the Government. Judicial Supremacy then is none other than the power of
judicial review under the constitution.
Yes; by looking at the records, it was determined that the Electoral Commission was the
sole judge of all contests relating to the election, returns, and qualifications of members
of the National Assembly, and that consequently, the confirmation (Resolution no.8)
made by the National Assembly is considered to be of no value with regards to the issue.

Notes

In times of social disquietude or political excitement, the great landmarks of the

constitution are apt to be forgotten or marred, if not entirely obliterated. In cases of

conflict, the judicial department is the only constitutional organ which can be called upon
to determine the proper allocation of powers between the several departments and among
the integral or constituent units thereof. (oo, dito sa case na ito galing yung paboritong
i-cite ng mga justices.)