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Angara v Electoral Commission

Angara v Electoral Commission

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Published by Ana Marie Lomboy

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Published by: Ana Marie Lomboy on Jul 16, 2011
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07/16/2011

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JOSE ANGARA, petitioner, vs. THE ELECTORAL COMMISSION, PEDRO YNSUA, MIGUEL CASTILLO, AND DIONISIO C.

MAYOR, respondents July 15, 1936 Ponente: Laurel, J. Nature of the case: ORIGINAL ACTION in the Supreme Court. Prohibition Godofredo Reyes for petitioner; Solicitor-General for respondent Electoral Commission; Pedro Ynsua in his own behalf; No appearance for other respondents.

Facts of the Case: 1. Jose Angara, petitioner, won against Pedro Ynsua, Miguel Castillo, and Dionisio Mayor in the election held for the position of members of the National Assembly for the first district of the Province of Tayabas. 2. On October 7, 1935, the provincial board of canvassers proclaimed the petitioner as member-elect of the National assembly and subsequently took his oath of office on November 15, 1935. 3. On December 3, 1935, the National Assembly in session passed Resolution no. 8 (text in Spanish), which confirmed the election of members against whom no protests had been filed. 4. On December 8, Pedro Ynsua filed a Motion of Protest against the election of Jose Anagara, which requested that the former be declared the electmember of the National Assembly for the first district province of Tayabas or that the election of the said position be nullified (**no reason was stated in the case as to why the respondent contested the election of the petitioner) 5. On December 4 and 6, 1935, the three justices of the Supreme Court and the six members of the Natioanl Assembly were designated to their respective positions in the Electoral Commission. 6. On December 9, 1935, the Electoral Commission adopted a resolution, paragraph 6 of which specified December 9 as the last date for the filing of protests against elections and that protests filed after the said date will not be entertained. 7. On December 20, 1935, Jose Angara filed a Motion to Dismiss the Protest but was denied.

The Supreme Court has jurisdiction over the Electoral Commission. Art VIII of “our Constitution” (The case was decided on 1936 so the term may have been used to refer to the 1935 Constitution. Issues of the Case: 1. conflicting claims of authority under the fundamental law between departmental powers and agencies of the government are necessarily determined by the judiciary in justiciable and appropriate cases.8. which is a constitutional organ that is subject to the provisions of the Constitution because it derives its power from the same. The power of the judiciary to determine the proper allocation of powers between the different branches of the government is granted by clear implication from Sec 2. Whether or not the Supreme Court has jurisdiction over the Electoral Commission and the subject matter of the controversy upon the foregoing related facts. The Court further emphasized that the judiciary is the only constitutional organ which is vested with the authority to determine the proper allocations of powers between the several departments and among the integral or constituent units thereof. one of the respondents. Held: For Issue 1 (jurisdiction of the SC over the EC) 1. 2. The petitioner then filed the present case asking for the issuance of a writ of prohibition to restrain and prohibit the Electoral Commission. from taking further cognizance of the protest filed by Pedro Ynsua against the election of said petitioner as member of the National Assembly for the first assembly district of the Province of Tayabas. 3. The Electoral Commission is not a separate department f the government and even if it were. states that the judiciary has jurisdiction about questions of law and those related to the constitutionality or validity of laws and other legal statutes). 4. . Whether or not the Electoral Commission acted without or in excess of its jurisdiction in assuming to take cognizance of the protest filed by the respondent despite the confirmation made by the National Assembly. which. in summary and in relation to the case. 2.

returns.Note: The exercise of the power of the judiciary to allocate constitutional boundaries in determining the allocation of powers between the different branches of the government is not an assertion of superiority but is a mere assertion of the solemn and sacred obligation assigned to it by the Constitution – meaning of judicial supremacy. which made each house of the Philippine Legislature as the sole judge of the election. returns. Sec. . 4. 2. as was done by the National Assembly on December 3. returns. Ruling: The petition for a writ of prohibition against the Electoral Commission is hereby denied. which leaves the Electoral Commission as the sole judge of the election. For Issue 2 (excess of jurisdiction) 1. and qualifications of the members of the National Assembly. When the National Assembly transferred all the powers previously exercised by the legislature with respect to contests relating to the election. which includes the power to determine the deadline for the filing of protests. it also transferred the authority to determine the rules and regulations surrounding the manner of filing protests. and Section 478 of Act no. 3387. which prescribed the rules and regulations of filing a protest. 3. and qualifications of its members to the Electoral Commission through the 1935 Constitution. and qualifications of its members. The confirmation made by the National Assembly does not and can not deprive of the Electoral Commission of its power to prescribe the deadline for the filing of protests related to tlections. 18 of the Jones Law. and he would only act on contests or protests regarding the elections. The intention of the framers showed that there is no need on the part of the Electoral Commission for confirmation. were repealed by the Constitution. with costs against the petitioner.

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