Angara v. Electoral Commission, 63 Phil. 139 (1936)
Angara v. Electoral Commission, 63 Phil. 139 (1936)
Angara v. Electoral Commission, 63 Phil. 139 (1936)
139 (1936)
FACTS:
Jose Angara and Pedro Ynsua, Miguel Castillo and Dionisio Mayor were candidates voted for the position
of member of the National Assembly for the 1st district of Tayabas province.
On Oct 17 1935, the provincial board of canvassers proclaimed Angara as member-elect of the Nat'l
Assembly for garnering the most number of votes. He then took his oath of office on Nov 15th. On Dec
3rd, Nat'l Assembly passed Res. No 8 which declared with finality the victory of Angara. On Dec 8, Ynsua
filed before the Electoral Commission a motion of protest against the election of Angara, that he be
declared elected member of the Nat'l Assembly. Electoral Commission passed a resolution in Dec 9th as
the last day for the filing of the protests against the election, returns and qualifications of the members of
the National Assembly. On Dec 20, Angara filed before the Elec. Commission a motion to dismiss the
protest that the protest in question was filed out of the prescribed period. The Elec. Commission denied
Angara's petition.
Angara prayed for the issuance of writ of prohibition to restrain and prohibit the Electoral Commission
taking further cognizance of Ynsua's protest. He contended that the Constitution confers exclusive
jurisdiction upon the said Electoral Commissions as regards the merits of contested elections to the Nat'l
Assembly and the Supreme Court therefore has no jurisdiction to hear the case.
ISSUE:
Whether or not the SC has jurisdiction over the Electoral Commission and the subject matter of the
controversy;
Whether or not The Electoral Commission has acted without or in excess of its jurisdiction.
RULING:
In this case, the nature of the present controversy shows the necessity of a final constitutional arbiter to
determine the conflict of authority between two agencies created by the Constitution. 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." (Sec 4 Art. VI 1935 Constitution). It is held, therefore, that the
Electoral Commission was acting within the legitimate exercise of its constitutional prerogative in
assuming to take cognizance of the election protest filed by Ynsua.