You are on page 1of 2

Angara v.

Electoral Commission
Facts: Petitioner Jose A. Angara and the respondents
Pedro Ynsua, Miguel Castillo, and Dionisio Mayor were
candidates voted for the position of members of the
National Assembly for the first district of Tayabas. On
Oct. 7, 1935, the provincial board of canvassers
proclaimed Angara as member-elect of the National
Assembly and on Nov. 15, 1935, he took his oath of
office. On Dec. 3, 1935, the National Assembly passed
Resolution No. 8, which in effect, fixed the last date to
file election protests. On Dec. 8, 1935, Ynsua filed
before the Electoral Commission a "Motion of Protest"
against Angara and praying, among other things, that
Ynsua be named/declared elected Member of the
National Assembly or that the election of said position
be nullified. On Dec. 9, 1935, the Electoral Commission
adopted a resolution (No. 6) stating that last day for
filing of protests is on Dec. 9. Angara contended that
the Constitution confers exclusive jurisdiction upon the
Electoral Commission solely as regards the merits of
contested elections to the National Assembly and the
Supreme Court therefore has no jurisdiction to hear the
case.
Issue: WON the Supreme Court has jurisdiction over
the Electoral Commision and the subject matter of the
controversy upon the foregoing related facts.

Held: The Electoral Commission is acting within the


legitimate exercise of its constitutional prerogative in
assuming to take cognizance of the protest filed by the
respondent Pedro Ynsua against the election of the
herein petitioner, Jose A. Angara, and that the
resolution of the National Assembly on Dec. 3, 1935,
cannot in any manner toll the time for filing protest
against the election, returns, and qualifications of the
members of the National Assembly, nor prevent the
filing of protests within such time as the rules of the
Electoral Commission might prescribe. Separation of
powers states that each department of the government
is supreme within his own sphere and jurisdiction but it
does not follow that the three powers are to be
separate because the constitution has provided a
system of checks and balances to secure coordination
in the various parts of the government. Judicial
department is the only constitutional organ which can
be called upon to determine the proper allocation of
powers between the several departments. Although the
Electoral Commission may not be interfered with, when
and while acting within the limits of its authority, it does
not follow that it is beyond the reach of the
constitutional mechanism adopted by the people and
that it is not subject to constitutional restrictions