Title: Angara vs.

Electoral Commission
Date: July 15, 1936
Petitioner: Jose A. Angara
Respondent: Electoral Commission, private: Pedro Ynsua
Ponente: Justice Laurel
Digest by Suing, Lemarie

The case is about the conflict of powers between the National Assembly and the Electoral Commission
regarding the election of Angara into the Assembly. The National Assembly confirmed Angara’s election by passing
Resolution no. 8. Subsequently, the Electoral Commission entertained a motion to protest filed against Angara. The
court ruled that the Electoral Commission acted within its jurisdiction. It held that all the National Assembly’s powers
relating to elections, returns, and qualifications of its members, by virtue of sec. 4 Art VI of the 1935 constitution, were
transferred ex necessitate rei (from the necessity/in totality) to the Commission.

I. Facts
On Oct. 7, 1935, Jose Angara was proclaimed to have garnered the most number of votes in the Sept. 17,
1935 elections for the position of member of the National Assembly for the first district of Tayabas.
On Dec. 3, The National Assembly passed Res. no. 8 confirming the uncontested election of Angara.
On Dec. 8, Pedro Ynsua filed a motion of protest against the election of Angara praying that Ynsua be
declared member of the National Assembly or that the elections be nullified.
On Dec. 9, the Electoral Commission passed a resolution, paragraph 6 of which sets the time for filing
protests on or before Dec. 9, 1935 (the day they passed this resolution). They took cognizance of Ynsua’s protest.
Angara filed a motion to dismiss protest which the Commission denied. Hence this petition for prohibition seeking to
restrain respondent Electoral Commission from taking cognizance of private respondent Ynsua’s motion of protest.

II. Claims
Petitioner Angara: (i) that the Electoral Commission has no jurisdiction to regulate proceedings of election
contests (in passing its resolution prescribing the time for filing motions of protest), said power to regulate being
exclusive to the legislative.
Respondent Electoral Commission and Ynsua:: (i) that the Electoral Commission, in passing that resolution,
acted within its jurisdiction and in the legitimate exercise of its implied powers granted it by the constitution to adopt
rules and regulations regarding “all contests relating to election, returns, and qualifications of the members of the
National Assembly”.

III. Issue/s
1. Whether or not the Supreme Court has jurisdiction over the Electoral Commission and the subject matter
of this case.
2. Whether or not the Electoral Commission acted within its jurisdiction in taking cognizance of Ynsua’s
motion of protest despite Res. no. 8 by the National Assembly.

IV. Ruling/Ratio
 1. YES, the SC has jurisdiction. Sec. 2 Art VIII of the constitution has conferred to the court the power of
judicial review. In cases of conflict, the court held that it is the judicial department which can be called upon to
determine the proper allocation of powers between the different branches of government by interpreting the
constitution.
However, this power is limited to the presence of an actual case or controversy and further, to the lis mota
which must be the constitutional question raised. The actual controversy here is the conflict of a grave constitutional
nature between the National Assembly and the Electoral Commission. There is a conflict of authority between these
two agencies created by the constitution. The lis mota is the constitutional question of whether or not the Electoral
Commission acted within its jurisdiction stated in sec. 4 Art. VI of the constitution.
The court held that it 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”.
2. YES, the Electoral Commission acted within its jurisdiction. The members of the 1934 Constitutional
Convention intended that the power to decide contents relating to the election, returns, and qualifications of
members of the National Assembly be conferred to the Commission (This was to secure the impartiality and
non-partisan settlement of membership in the National Assembly. If the National Assembly is to regulate the election
of its own members, then the elections are susceptible to partisan politics). The express lodging of that power (in
sec. 4 Art. VI) is an implied denial of the National Assembly’s exercise of said power.
The National Assembly, in confirming the uncontested election of Angara by passing Res. no. 8, does not
deprive the Electoral Commission of its power to prescribe the time (or set the deadline) within which protests against
the election can be filed. Ynsua filed the protest within the prescribed time therefore the Commission has
acted within the exercise of its constitutional prerogative in taking cognizance of Ynsua’s motion of protest.