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ANGARA V ELECTORAL COMMISSION [63 PHIL.

139 1936]
Nature of the Cae! Original Action to the SC. Petition for the issuance of a writ of
prohibition to restrain and prohibit the ELECOM from taking further cognizance of the
protest led b! Pedro "nsua against the election of the petitioner as a member of the
#A
"a#t of the Cae! $he new constitution for the %ndependent Philippine
Commonwealth was &ust promulgated. $he petitioner' Angara' ran for the position of
representati(e of the )irst *istrict of the Pro(ince of $a!abas to the #A Septmeber +,'
+-./ against "nsua 0one of the respondents1 and others. On October ,' he was
proclaimed b! the pro(incial board of can(assers as the candidate who won the most
(otes and thus the winner. 2e took his oath of o3ce on #o(ermber +/ 0the start of the
Commonwealth1 and was conrmed b! the #A on *ecember . as an uncontested
member of the #A. Also on this da!' 4es56 was passed b! the #A' conrming the
membership of nonprotested elections of members of the #A and' in e7ect' limiting
the time for presentation of protests. 2owe(er' there was the ELECOM' which was a
constitutional bod! in(ested with the &urisdiction to decide 8all cases relating to the
election' returns' and 9ualications of the members of the #A:' was &ust being formed
on *ecember ; and < and &ust met for the rst time on *ecember -' =ing that da! as
the last da! for the ling of election protests. "nsua led his 8Motion of Protest: to the
ELECOM on *ecember 6' a da! before the said bod! ended the period for ling of
election protest.
After that' Angara led a 8Motion to *ismiss the Protest: to the ELECOM on the
grounds that he was alread! conrmed a member of the #A through the 4es56 and
through that resolution' the prescribed period for ling of protests had alread! ended
on *ecember .' and the respondent was late in ling his protest because he led the
protest after *ecember ..
"nsua led an 8Answer to the Motion of *ismissal: arguing that there was no
constitutional or legal pro(ision which stated that members of the #A cannot be
contested after conrmationof the #A. Angara replied to this 8Answer: but the
ELECOM promulgated a resolution den!ing the petitioner>s 8Motion to *ismiss the
Protest:.
$he Petitioner now les a protest to the SC' 9uestioning the &urisdiction of the ELECOM
o(er the case' arguing that?
the ELECOM has &urisdiction o(er the merits of contested elections to the #A
but the #A has the power to regulate the proceedings of the #A' granted that
ELECOM is part of the #A. ELECOM could onl! regulate its proceedings if the #A
did not pro(ide for it.
4es56 is (alid and should be respected' granted that #A is the onl! bod! that
could regulate the proceedings of the ELECOM
@nder Par+. of A+ of Ordinance appended to the Constitution and par<Art, of
the $!dingsBMc*u3e Law as well as A+ and C of art D%%% of the Constitution' SC
has &urisdiction to pass upon the fundamental 9uestions raised in this issue
because it in(ol(es the interpretation of the Constitution of the Philippines
$he SolicitorBEeneral responded on behalf of ELECOM arguing that?
ELECOM is a constitutional bod! in(ested with the &urisdiction to decide 8all
contests relating to the election' returns' and 9ualication of the members of
the #A: and that *ec - was the date =ed b! ELECOM as the last da! of ling for
protest and its resolution dated Fanuar! C.' +-.< was an act of its legitimate
Codes: ELECOM (Election Commission); NA (National Assembly); Res#8 (Resolution No. 8); SC
(Su!eme Cou!t)
e=ercise of 9uasiB&udicial functions. Said act is be!ond cognizance or control of
SC.
4es56 did and could not depri(e ELECOM of its &urisdiction to take cognizance of
election protests led within the limit that the ELECOM would set.
ELECOM is not an 8inferior tribunal' or corporation' or board' or person:
"nsua led an anwer arguing that?
4es56 did not limit his ling for protest for ELECOM =ed the deadline on *ec -
and not on the passage of 4es56' which was on *ec.
4espondent led protest before ELECOM ended the period for ling election
complaints
ELECOM ac9uired &urisdiction o(er election protest and Fan C. resolution of
ELECOM den!ing the 8Motion to *ismiss the Protest: was not re(iewable b! the
SC b! means of a writ of prohibition since it was part of ELECOM>s &urisdiction
#o constitutional nor legal pro(ision re9uires the conrmation of members of
the #A and that the said conrmation could not limit the period for ling protest
ELECOM is an independent constitutional entit! with 9uasiB&udicial functions and
thus' its decisions are nal and unappealableG also ELECOM is a constitutional
creation which is not an inferior tribunal' or corporation' board' or person and is
not sub&ect to a writ of prohibition from the SC
Par<'art, of $!dingsBMc*u3e Law is not applicable
%ssues?
+. HO# the SC has &urisdiction o(er the ELECOM and the sub&ect matter of the
contro(ers!
C. HO#' if e(er the rst is granted' ELECOM acted within or without its &urisdiction
in assuming cognizance of the protest led against the election of Angara
2eld I 4atio?
+. "es. $he SC has &urisdiction o(er the ELECOM? separation of powers granted b!
Consti 0through separate articles for each branch1 but check and balances
maintain coordination among the branches. Hhen there are conJicts between
the boundaries of powers and functions of each branch' the Fudiciar! has the
power to re(iew and resol(e these conJicts through Fudicial 4e(iew 0referred to
as Fudicial Supremac!1. $his howe(er is limited to actual cases and
contro(ersies.
C. "es. ELECOM acted within its &urisdiction since ELECOM is recognized as an
independent 9uasiB&udicial bod! which is not an inferior tribunal' or corporation'
board' or person' and is granted the powers to be the sole &udge of all contests
relating to the election' returns and 9ualications of members of the #A. $he
present constitution granted the ELECOM with all the powers e=ercised b! the
legislature relating to the said function of ELECOM' and this includes the
regulation of the rules and procedures of election protests. $he conrmation of
#A of its members is not re9uired and does not limit the ELECOM of its power to
= dates for election protest' or else this would undermine the power and
functions of the ELECOM.
*EC%? petition for writ of prohibition denied' with costs against the petitioner.
Codes: ELECOM (Election Commission); NA (National Assembly); Res#8 (Resolution No. 8); SC
(Su!eme Cou!t)
Codes: ELECOM (Election Commission); NA (National Assembly); Res#8 (Resolution No. 8); SC
(Su!eme Cou!t)