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Angara vs Electoral Commission (G.R. No.

L-45081)
Separation of Powers

FACTS: In the elections of September 1935, Jose Angara, Pedro Ynsua, Miguel Castillo and Dionisio Mayor
were candidates voted for the position of member of the National Assembly in the first district of Tayabas.
The petitioner was proclaimed member-elect for the said district for receiving the most number of votes
and thereafter took his oath in office. A Motion of Protest was filed by Ynsua against the election of the
petitioner. The petitioner countered this with a Motion to Dismiss the Protest which was denied by the
Electoral Commission.

ISSUES: Whether the Supreme Court has jurisdiction over the Electoral Commission and the subject matter
of the controversy; and

Whether the said Electoral Commission acted without or in excess of its jurisdiction in assuming cognizance
of the protest filed over the election of herein petitioner.

HELD: The National Assembly operates as a check on the Executive in the sense that its consent through
its Commission on Appointments is necessary in the appointments of certain officers; and the concurrence
of a majority of all its members is essential to the conclusion of treaties. Furthermore, its power to determine
what courts other than the Supreme Court shall be established, to define their jurisdiction and to
appropriate funds for their support, the National Assembly controls the judicial department to a certain
extent. The Assembly also exercises the judicial power of trying impeachments. The Judiciary, in turn, with
the Supreme Court as the final arbiter effectively checks the other departments in the exercise of its power
to determine the law, and hence to declare executive and legislative acts void if violative of the
Constitution. This power of has been stated in Section 2, Article VIII of the Constitution.

Section 4, Article VI of the Constitution provides that “x x x The Electoral Commission shall be the sole judge
of all contests relating to the election, returns and qualifications of the members of the National Assembly.”
In view of the deliberations of the framers of the Constitution, it is held that the Electoral Commission was
acting within the legitimate exercise of its constitutional prerogative in assuming to take cognizance of the
protest filed by the respondent Ynsua. The petition of writ of prohibition against the Electoral Commission is
hereby denied.

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.