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Angara v.

Electoral Commission, against the election of the petitioner Angara, and that the earlier resolution of the National
G.R. No. L-45081, July 15, 1936 Assembly cannot in any manner toll the time for filing election protests against members
of the National Assembly, nor prevent the filing of a protest within such time as the rules
of the Electoral Commission might prescribe.
DECISION
(En Banc) The grant of power to the Electoral Commission to judge all contests relating to
the election, returns and qualifications of members of the National Assembly, is intended
LAUREL, J.: to be as complete and unimpaired as if it had remained originally in the legislature. The
express lodging of that power in the Electoral Commission is an implied denial of the
I. THE FACTS exercise of that power by the National Assembly. xxx.

Petitioner Jose Angara was proclaimed winner and took his oath of office as [T]he creation of the Electoral Commission carried with it ex necesitate rei the
member of the National Assembly of the Commonwealth Government. On December 3, power regulative in character to limit the time with which protests intrusted to its
1935, the National Assembly passed a resolution confirming the election of those who cognizance should be filed. [W]here a general power is conferred or duty enjoined, every
have not been subject of an election protest prior to the adoption of the said resolution. particular power necessary for the exercise of the one or the performance of the other is
also conferred. In the absence of any further constitutional provision relating to the
On December 8, 1935, however, private respondent Pedro Ynsua filed an election procedure to be followed in filing protests before the Electoral Commission, therefore, the
protest against the petitioner before the Electoral Commission of the National Assembly. incidental power to promulgate such rules necessary for the proper exercise of its
The following day, December 9, 1935, the Electoral Commission adopted its own exclusive power to judge all contests relating to the election, returns and qualifications of
resolution providing that it will not consider any election protest that was not submitted on members of the National Assembly, must be deemed by necessary implication to have
or before December 9, 1935. been lodged also in the Electoral Commission.

Citing among others the earlier resolution of the National Assembly, the petitioner
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sought the dismissal of respondent’s protest. The Electoral Commission however denied
his motion. FACTS:
In the elections of Sept 17, 1935, Angara, and the respondents, Pedro Ynsua et al. were
II. THE ISSUE
candidates voted for the position of member of the National Assembly for the first district
of the Province of Tayabas. On Oct 7, 1935, Angara was proclaimed as member-elect of
Did the Electoral Commission act without or in excess of its jurisdiction in taking
the NA for the said district. On November 15, 1935, he took his oath of office. On Dec 3,
cognizance of the protest filed against the election of the petitioner notwithstanding the
1935, the NA in session assembled, passed Resolution No. 8 confirming the election of
previous confirmation of such election by resolution of the National Assembly?
the members of the National Assembly against whom no protest had thus far been filed.
On Dec 8, 1935, Ynsua, filed before the Electoral Commission a “Motion of Protest”
III. THE RULING
against the election of Angara. On Dec 9, 1935, the EC adopted a resolution, par. 6 of
which fixed said date as the last day for the filing of protests against the election, returns
[The Court DENIED the petition.]
and qualifications of members of the NA, notwithstanding the previous confirmation made
by the NA. Angara filed a Motion to Dismiss arguing that by virtue of the NA proclamation,
NO, the Electoral Commission did not act without or in excess of its
Ynsua can no longer protest. Ynsua argued back by claiming that EC proclamation
jurisdiction in taking cognizance of the protest filed against the election of the
governs and that the EC can take cognizance of the election protest and that the EC
petitioner notwithstanding the previous confirmation of such election by resolution
cannot be subject to a writ of prohibition from the SC.
of the National Assembly.

The Electoral Commission acted within the legitimate exercise of its constitutional
prerogative in assuming to take cognizance of the protest filed by the respondent Ynsua
ISSUES:
Whether or not the SC has jurisdiction over such matter.
Whether or not EC acted without or in excess of jurisdiction in taking cognizance of the
election protest.

HELD:
The SC ruled in favor of Angara. The SC emphasized that in cases of conflict between
the several departments and among the agencies thereof, the judiciary, with the SC as
the final arbiter, is the only constitutional mechanism devised finally to resolve the conflict
and allocate constitutional boundaries.
That judicial supremacy is but the power of judicial review in actual and appropriate cases
and controversies, and is the power and duty to see that no one branch or agency of the
government transcends the Constitution, which is the source of all authority.
That the Electoral Commission is an independent constitutional creation with specific
powers and functions to execute and perform, closer for purposes of classification to the
legislative than to any of the other two departments of the government.
That the Electoral Commission is the sole judge of all contests relating to the election,
returns and qualifications of members of the National Assembly.