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ANGARA VS ELECTORAL COMMISSION

Posted by kaye lee on 3:28 PM


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.
Categories: Constitutional Law 1