Angara Vs Electoral Commission

Angara vs Electoral Commission
This petition is a writ of prohibition to restrain and prohibit the Electoral Commission
Facts:
In the elections of Sept. 17, 1935, petitioner Jose A. Angara and the respondents Pedro
Ynsua, Miguel Castillo, and Dionisio Mayor were candidates for the position of members of the
National Assembly for the first district of Tayabas.
On Oct. 7, 1935, the provincial board of canvassers proclaimed Angara as member-elect

of the National Assembly and on Nov. 15, 1935, he took his oath of office.
On Dec. 3, 1935, the National Assembly passed Resolution No. 8, which in effect, fixed
the last date to file election protests.
On Dec. 8, 1935, Ynsua filed before the Electoral Commission a “Motion of Protest”
against Angara and praying, among other things, that Ynsua be named/declared elected Member
of the National Assembly or that the election of said position be nullified.
On Dec. 9, 1935, the Electoral Commission adopted a resolution (paragraph 6 of which)

stating that last day for filing of protests is on Dec. 9.
In his writ of prohibition against Electoral Commission, Angara contended that the
Constitution confers exclusive jurisdiction upon the Electoral Commission solely as regards the
merits of contested elections to the National Assembly and the Supreme Court therefore has no
jurisdiction to hear the case.
Issue:
Whether or not the Supreme Court has jurisdiction over the Electoral Commission and
the subject matter of the controversy upon the foregoing related facts, and in the affirmative?
Whether or not the Electoral Commission is conferred by the Constitution or law to

exercise quasi-judicial function?
Ruling:
Yes.
The Supreme Court, speaking through Justice Laurel, teaches us that 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 checks
and balances to secure coordination in the workings of the various departments of the
government.
In cases of conflict between the several departments and among the agencies thereof, the
judiciary, with the Supreme Court as the final arbiter, is the only constitutional mechanism
devised finally to resolve the conflict and allocate constitutional boundaries.
The Constitution is a definition of the powers of government. Who is to determine the
nature, scope and extent of such powers? The Constitution itself has provided for the
instrumentality of the judiciary as the rational way. And when the judiciary mediates to allocate
constitutional boundaries, it does not assert any superiority over the other departments; it does
not in reality nullify or invalidate an act of the legislature, but only asserts the solemn and sacred
obligation assigned to it by the Constitution to determine conflicting claims of authority
under the Constitution and to establish for the parties in an actual controversy the rights
which that instrument secures and guarantees to them.
This is in truth all that is involved in what is termed "judicial supremacy" which
properly is the power of judicial review under the Constitution. Even then, this power of
judicial review is limited to actual cases and controversies to be exercised after full
opportunity of argument by the parties, and limited further to the constitutional question
raised.
In the case at bar, here is then presented an actual controversy involving as it does a
conflict of a grave constitutional nature between the National Assembly on one hand, and
the Electoral Commission on the other. Although the Electoral Commission may not be
interfered with, when and while acting within the limits of its authority, it does not follow that it
is beyond the reach of the constitutional mechanism adopted by the people and that it is not
subject to constitutional restrictions. The Electoral Commission is not a separate department
of the government, and even if it were, conflicting claims of authority under the
fundamental law between departmental powers and agencies of the government are
necessarily determined by the judiciary in justiciable and appropriate cases.
The court has jurisdiction over the Electoral Commission and the subject matter of the
present controversy for the purpose of determining the character, scope, and extent of the
constitutional grant to the Electoral Commission as “the sole judge of all contests relating to
the election, returns, and qualifications of the members of the National Assembly.”
The Electoral Commission was created to transfer in its totality all the powers
previously exercised by the legislature in matters pertaining to contested elections of its
members, to an independent and impartial tribunal. The express lodging of that power in the
Electoral Commission is an implied denial in the exercise of that power by the National
Assembly. And thus, it is as effective a restriction upon the legislative power as an express
prohibition in the Constitution.
Therefore, the incidental power to promulgate such rules necessary for the proper
exercise of its exclusive power to judge all contests relating to the election, returns, and
qualifications of members of the National Assembly, must be deemed by necessary implication
to have been lodged also in the Electoral Commission.
It appears that on Dec. 9, 1935, the Electoral Commission met for the first time and
approved a resolution fixing said date as the last day for the filing of election protests. When,
therefore, the National Assembly passed its resolution of Dec. 3, 1935, confirming the election of
the petitioner to the National Assembly, the Electoral Commission had not yet met; neither does
it appear that said body had actually been organized.
While there might have been good reason for the legislative practice of confirmation of
the election of members of the legislature at the time the power to decide election contests was
still lodged in the legislature, confirmation alone by the legislature cannot be construed as
depriving the Electoral Commission of the authority incidental to its constitutional power to be
“the sole judge of all contests…”, to fix the time for the filing of said election protests.
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, Pedro Ynsua against the election of the herein petitioner, Jose A. Angara, and
that the resolution of the National Assembly on Dec. 3, 1935, cannot in any manner toll the time
for filing protest against the election, returns, and qualifications of the members of the National
Assembly, nor prevent the filing of protests within such time as the rules of the Electoral
Commission might prescribe.
The petition for a writ of prohibition against the electoral commission is hereby denied,
with cost against the petitioner.
Doctrine:
1) Section 4 of Article VI of the Constitution - There shall be an Electoral Commission

composed of three Justices of the Supreme Court designated by the Chief Justice, and
of six Members chosen by the National Assembly, three of whom shall be nominated
by the party having the largest number of votes, and three by the party having the second
largest number of votes therein. The senior Justice in the Commission shall be its
Chairman, 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." It is imperative, therefore, that we delve into the origin and history of this
constitutional provision and inquire into the intention of its framers and the people who
adopted it so that we may properly appreciate its full meaning, import and significance.

Angara Vs Electoral Commission

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Angara Vs Electoral Commission

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Angara vs Electoral Commission

On Oct. 7, 1935, the provincial board of canvassers proclaimed Angara as member-elect

On Dec. 9, 1935, the Electoral Commission adopted a resolution (paragraph 6 of which)

Whether or not the Electoral Commission is conferred by the Constitution or law to

1) Section 4 of Article VI of the Constitution - There shall be an Electoral Commission

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