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G.R. No. 45081 SUMMARY ANGARA vs. ELECTORAL COMMISSION Syllabus, Decision, Opinions PDF
G.R. No. 45081 SUMMARY ANGARA vs. ELECTORAL COMMISSION Syllabus, Decision, Opinions PDF
Summary Cases:
Subject: Principle of separation of powers and checks and balances under a Republican system of
government; Judicial supremacy (Power of Judicial Review); Presence of an actual case or controversy;
Court has jurisdiction over Electoral Commission; Electoral Commission (Electoral tribunal) exercises
exclusive jurisdiction over all contests relating to the election, returns and qualifications of the legislative
members; Electoral Commission is independent and distinct from the legislative body; The Electoral
Commission has power to promulgate the rules necessary for the proper exercise of its exclusive power
to judge all election contests; Confirmation by the legislature of the election of its members cannot
deprive the Electoral Commission of the authority to judge election contests and, corollary to it, to fix the
time for the filing of election protests; Confirmation of the election of anylegislative member is not
required by the Constitution before he can discharge his duties as such member; The National Assembly
has no authority to fix the time for filing election protests against its members, the basis for its authority
having been repealed by the 1935 Constitution
Facts:
During the 1935 elections, the provincial board of canvassers, proclaimed petitioner Jose A. Angara as
member-elect of the National Assembly for the first assembly district of the Province of Tayabas. Angara
thereafter took his oath of office.
On December 3, 1935, the National Assembly passed Resolution No. 8 confirming the election of the
members of the National Assembly against whom no protest had thus far been filed.
Nevertheless, on December 8, 1935, respondent Pedro Ynsua filed before the Electoral Commission a
"Motion of Protest" against the election of Angara, and prayed that he (Ynsua) be declared elected
member of the National Assembly for the said district.
On December 9, 1935, the Electoral Commission adopted a resolution fixing the said date (Dec 9) as the
last day for the presentation of protests against the election of any of the members.
Angara filed before the Electoral Commission a "Motion to Dismiss the Protest", alleging that the protest
was filed out of the prescribed period.
Pedro Ynsua countered that there is no legal or constitutional provision barring the presentation of a
protest against the election of a member of the National Assembly, after confirmation.
The Electoral Commission denied Angaras "Motion to Dismiss the Protest."
Aggrieved, Angara filed before the Supreme Court a petition 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. Angara contends that under the Constitution, the power to regulate the proceedings of
said election contests has been reserved to the Legislative Department (the National Assembly).
The Solicitor-General, in behalf of the Electoral Commission, contends that the Resolution No 8 of the
National Assembly (confirming the election of its members against whom no protest has then been filed)
could not deprive the Electoral Commission of its jurisdiction to take cognizance of election protests filed
within the time that might be set by its own rules.
The Court reduced the issues as follows:
Does the Supreme Court have jurisdiction over the Electoral Commission and the subject matter of the
controversy
Did the Electoral Commission act without or in excess of its jurisdiction in taking cognizance of the
protest filed against Angara notwithstanding the previous confirmation of his election by resolution of the
National Assembly?
Held:
Principle of separation of powers and checks and balances under a Republican system of