ANGARA v.

ELECTORAL COMMISSION
JULY 15, 1986; J. LAUREL

SUMMARY: Petitioner Angara filed a writ of prohibition against Electoral Commission to

prevent it from recognizing Ynsua’s protest against him. He said that National Assembly’s
Resolution No. 8 (closing the protest period) is valid and thus Ynsua petition is out of period.
Ynsua contended that the deadline is Dec. 9 per Electoral Commission. Court ruled that
Electoral Commission should prevail because it is in its proper jurisdiction.

FACTS:
1935
• Sept 7 - Jose Angara was one of the candidates voted for the position of member of National
Assembly. He was proclaimed and took his oath on office.

• Dec 3 - National Assembly passed a resolution confirming no more protest was filed.

• Dec 8 - Pedro Ynsua, fellow candidate, filed before ELECTORAL COMMISSION, “Motion to
Protest”.

• Dec 9 - Electoral Commission adopted a resolution stating that final deadline for protest was
today.

• ANGARA: Resolution No. 8 of National Assembly was valid, thus fixing the deadline. Ynsua
protest was out of period.

• ELECTORAL COMMISSION: Denied.

ANGARA

A. The resolution of National Assembly has the effect of cutting off the power of the Electoral
Commission to entertain protests against election, returns and qualification of members of
the National Assembly.

B. Electoral Commission can only avail of such power if National Assembly did not avail it.

C. Resolution No. 8 is therefore valid and should be respected.

D. Supreme Court has jurisdiction to pass upon fundamental question raised because it
involves interpretation of the Constitution.

SOLICITOR GENERAL

a. Electoral Commission was created to decide on all contests relating to election […] of the
members of the National Assembly. It acted within jurisdiction when it filed resolution last
Dec. 9.

b. Dec. 3 Resolution of National Assembly did not deprive Electoral Commission jurisdiction
to recognize further election protest.

c. Electoral Commission has a quasi-judicial function as instrument of the Legislative Dept.

Hence, it is not an inferior tribunal.

YNSUA

a. The last day of filing of protest was December 9. The Electoral Commission was exercising
its jurisdiction.

b. Neither the law nor the Constitution requires confirmation by the National Assembly of the
election of its members. The confirmation does not limit period which protest may be filed.

c. Electoral Commission is an independent body whose decisions are final and unappealable.

ISSUE:
1. Has the SC have jurisdiction over Electoral Commission and the subject matter of
controversy upon the foregoing related facts?

2. Has the Electoral Commission acted without or in excess of jurisdiction to recognize the
Ynsua protest?

RULING:
1. Court has jurisdiction over the Electoral Commission.

• SEPARATION OF POWERS: There is a separation of powers among the three

branches. The Constitution has blocked out with deft strokes and in bold lines their
allotment of powers.

• FINAL ARBITER: In cases of conflict, the judicial department is the constitutional

organ to determine proper allocation of powers.

• JUDICIAL REVIEW: There is an express grant of judicial review on Sec 2, Art. 8,

Constitution.

• REQUISITES: Its exercise is limited “to actual cases to be exercised after full
opportunity of argument by the parties and limited further to the constitutional
question raised or the very lis nota presented”
• JUDICIAL SUPREMACY: When they assert this power, they are not superior. Rather,
they merely assert obligation assigned to them by the Constitution.
• There is necessity to decide on these cases.

• “Were we to decline to take cognizance of the controversy, who will determine the
conflict? And if the conflict were left undecided and undetermined, would not a void
be thus created in our constitutional system which may in the long run prove
destructive of the entire framework?” To ask these questions is to answer them.
• Natura vacuum aborret (Nature abhors a vacuum) — nature requires a space to be
filled with something.

2. Electoral commission acted within its jurisdiction

• Sec. 4, Art. 6, Constitution: Creation of Electoral Commission; “[…] shall be the sole
judge of all contests relating to the election, returns and qualifications of the members
of the NA”
• HISTORY: Each House shall be the judge of its own members.

• INTENT: remedy certain evils the framers were cognizant; “ultimate justice of the
people”
• It is not a separate branch, but when it acts within its jurisdiction, it acts as an
independent body. It is closer to the legislative department.

• Allowing National Assembly to cut off its powers and regulate the proceedings will
make the grant of powers to Electoral Commission ineffective.

• The dual authority will create a inevitable clash of powers from time to time.

DISPOSITION: Writ of Prohibition against Electoral Commission denied.