Separation of Powers

FACTS: In the elections of September 1935, Jose Angara, Pedro Ynsua, Miguel
Castillo and Dionisio Mayor were candidates voted for the position of member of the
National Assembly in the first district of Tayabas. The petitioner was proclaimed
member-elect for the said district for receiving the most number of votes and
thereafter took his oath in office. A Motion of Protest was filed by Ynsua against the
election of the petitioner. The petitioner countered this with a Motion to Dismiss the
Protest which was denied by the Electoral Commission.

ISSUES: Whether the Supreme Court has jurisdiction over the Electoral Commission
and the subject matter of the controversy; and

Whether the said Electoral Commission acted without or in excess of its jurisdiction in
assuming cognizance of the protest filed over the election of herein petitioner.

HELD: 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.