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ANGARA VS ELECTORAL COMMISSION

G.R. No. L-45081 July 15 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.