Angara vs. Electoral Commission, G.R. No. L-45081, July 15, 1936.

SEPTEMBER 18, 2018

FACTS:
The case was an original action filed by Jose Angara for the issuance of writ of prohibition to restrain
and prohibit the Electoral Commission (EC) from taking further cognizance of the protest filed by
Pedro Ynsua against the election of the former.
Jose Angara and Pedro Ynsua, et.al., were candidates for the position of National Assembly member
for 1st district of Tayabas Province.
On October 7, 1935, Provincial Board of Canvassers proclaimed Angara as the winner. Angara then
took his oath of office. National Assembly passed Resolution No. 8 (Confirming the election of
members of the National Assembly against whom no protest had been filed)
Subsequently, Respondent Ynsua filed before the Electoral Commission a “Motion of Protest” against
the election of Angara. Electoral Commission adopted a resolution, paragraph 6 of which provides:
“The commission will not consider any protest that is not submitted on or before this day (Dec. 9)”
Angara filed before the Electoral Commission a “Motion to dismiss the protest” on the ground that it
must uphold Resolution No. 8 of National Assembly. Ynsua countered that there is no constitutional
prohibition barring the filing of protest.
The Electoral Commission promulgated a resolution denying the “Motion to dismiss the Protest” filed
by Angara.
ISSUES:
1. WoN the Supreme Court has jurisdiction over the Electoral Commission as well as the subject
matter of the controversy (Resolution of National Assembly or Resolution of EC) – YES.
2. WoN the Electoral Commission acted without or in excess of its jurisdiction when: (1)it assumed
cognizance of the protest
despite the previous confirmation by the National Assembly; (2) it adopted its resolution in Dec. 9 –
NO.
3. WoN Resolution No. 8 can “nullify” filing of protest or toll the time of filing protest effectively
rendering the resolution of the Electoral Commission moot – NO.
RATIO:
1. On judicial review
“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 several departments and among the integral
or constituent units thereof.”
Sec. 4 of Art VI provides EC the sole power of deciding such matters. Also, from the transcript of the
Framers’ discussion, it is clearly the intention of the Framers to give EC “sole” jurisdiction over
election protests.
Each department of the government has exclusive cognizance of powers within its jurisdiction and is
supreme within its own sphere but it does not follow that the Constitution intended them to be
absolutely unrestrained and independent of each other.
Constitution institutes the system of checks and balances. Moderating power of the court is granted
by clear implication from section 2 article VIII of the Constitution.
The judiciary does not intend to assert superiority over other departments or deliberately nullify of
invalidate acts of the legislature. It merely asserts the obligation assigned to it by the Constitution to
determine conflicting claims for authority under the Constitution and establish rights for the parties.
“Power of judicial review is limited only to actual cases and controversies…and limited further to the
constitutional question raised or the very lis mota presented.”
2. On the legality of the Electoral Commission’s acts
National Assembly has no jurisdiction over election protests so it follows that they don’t have the
authority to prescribe the time or prevent the filing of protest. Separation within same branch of
government.
Electoral Commission acted within the legitimate exercise of its constitutional prerogative. It acted
within its jurisdiction. The EC’s resolution will stand. National Assembly’s Resolution No. 8 should
neither prevent the filing of protest within the time prescribed in EC’s resolution nor “toll the time” in
filing protests.