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Constititon Cases Rulings 1. Angara Vs Electoral Commission GR No. L-45081, July 15, 1936

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CONSTITITON CASES RULINGS

1. ANGARA VS ELECTORAL COMMISSION GR NO. L-45081, July 15, 1936

Doctrine: The separation of powers is a fundamental principle in our system of government. It


obtains not through express provision but by actual division in our Constitution. Each department of
the government has exclusive cognizance of matters within its jurisdiction, and is supreme within its
own sphere. But it does not follow from the fact that the three powers are to be kept separate and
distinct that the Constitution intended them to be absolutely unrestrained and independent of each
other. The Constitution has provided for an elaborate system of check and balances to secure
coordination in the workings of the various departments of the government.

ELD: The National Assembly operates as a check on the Executive in the sense that its consent
through its Commission on Appointments is necessary in the appointments of certain officers; and
the concurrence of a majority of all its members is essential to the conclusion of treaties.
Furthermore, its power to determine what courts other than the Supreme Court shall be
established, to define their jurisdiction and to appropriate funds for their support, the National
Assembly controls the judicial department to a certain extent. The Assembly also exercises the
judicial power of trying impeachments. The Judiciary, in turn, with the Supreme Court as the final
arbiter effectively checks the other departments in the exercise of its power to determine the law,
and hence to declare executive and legislative acts void if violative of the Constitution. This power of
has been stated in Section 2, Article VIII of the Constitution.

Section 4, Article VI of the Constitution provides that “x x x The Electoral Commission shall be the
sole judge of all contests relating to the election, returns and qualifications of the members of the
National Assembly.” In view of the deliberations of the framers of the Constitution, it is held that the
Electoral Commission was acting within the legitimate exercise of its constitutional prerogative in
assuming to take cognizance of the protest filed by the respondent Ynsua. The petition of writ of
prohibition against the Electoral Commission is hereby denied.

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