Angara vs.

Electoral Commission, 63
Phil 139 (1936)
ISSUE: Whether or not The Electoral Commission has acted without or in excess of its
jurisdiction.

FACTS: In the elections of Sept. 17, 1935, petitioner Jose A. Angara and the respondents
Pedro Ynsua, Miguel Castillo, and Dionisio Mayor were candidates 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.

DECISION: Dismissed

RATIO DECIDENDI: 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.