POLITICAL LAW 1 - III.

JUDICIAL REVIEW
CASE #1/A
JOSE A. ANGARA, petitioner (PETITION DISMISSED W/ COSTS)
vs.
THE ELECTORAL COMMISSION et al., respondent (WON CASE)
GR. No. L-45081 | July 15, 1936
(Commonwealth; Manuel L. Quezon; 1935-1944)

LAUREL, J:

THESIS STATEMENT:
Jose Angara filed a writ of prohibition to restrain the Electoral Commission from taking further cognizance of
the protest filed by Pedro Ynsua against the election of said petitioner as member-elect of the National
Assembly for the first district of the Province of Tayabas.
FACTS:
(1) On the September 17, 1935 elections, the petitioner, Jose Angara with respondents Pedro Ynsua,
and two others, were candidates to be voted for the position of member of the National Assembly;
(2) Angara had the most votes and was proclaimed as member-elect of the National Assembly for the said
district, he then took oath of office;
(3) December 3 – National Assembly passed the Resolution No. 8 confirming that no protest has
been presented against deputies.
(4) December 8 – Ynsua filed before the Electoral Commission a “Motion of Protest” against the
election of Angara, saying that Ynsua be declared member-elect of the National Assembly instead;
(5) In response, Angara filed before the Electoral Commission a “Motion to Dismiss the Protest”
arguing that:
- Resolution No. 8 prescribes the period of time in which protests against the election of its
“member” can be presented yet the said protest of Ynsua was filed out of the prescribed
period and therefore must be dismissed;
(6) Ynsua then filed an “Answer to the Motion of Dismissal” arguing that there is NO LEGAL OR
CONSTITUTIONAL PROVISION BARRING THE PRESENTATION OF A PROTEST;
(7) January 23, 1936 – Electoral Commission denied Angara’s “Motion to Dismiss the Protest”.
ARGUMENTS:

PETITIONER
 Constitution states that: the power to regulate
proceedings of said election is exclusive to
the Legislative Department or the National
Assembly (NA) alone;
 Electoral Commission may regulate
proceedings only if the National Assembly
has not availed of its power to regulate such
proceedings;
 The Supreme Court has jurisdiction over the
issues because it involves an interpretation of
the Constitution of the Philippines.
RESPONDENT
 The Electoral Commission was created by
the Constitution as an instrumentality
(agency) of the Legislative Department (NA)
vested with jurisdiction to decide “all
contests relating to the election, returns,
and qualifications of the members of the
National Assembly”, therefore, said act is
beyond the control of the Supreme Court.
 That the Electoral Commission is vested with
quasi-judicial functions;

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 POLITICAL LAW 1 - III. JUDICIAL REVIEW
ISSUES:
1. Does the Supreme Court have jurisdiction over the Electoral Commission and the subject matter of the
controversy?
2. Whether or not the said Electoral Commission acted within its jurisdiction in taking cognizance
of the protest filed against the petitioner despite the resolution of the National Assembly confirming the
election of petitioner.
RULING:
1. Yes. The court has jurisdiction in terms 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 the exercise their jurisdiction in taking cognizance,
and the Resolution No. 8 of cannot toll the time nor prevent the filing of protests against the
elections of the member of the National Assembly.
DECISION:
The petition for a writ of prohibition against the Electoral Commission is HEREBY DENIED, with costs against
the petitioner.
THE COURT RULED IN FAVOR OF THE RESPONDENTS.
DOCTRINE/PRINCIPLE:
The Doctrine/Principle of Separation of Powers proclaims that each of the three branches of government
has exclusive cognizance of and is supreme in matters falling within its own constitutionally allocated sphere.
However, the three powers must be kept separate and distinct that the Constitution intended them to be
independent of each other. The Constitution has provided an elaborate system of checks and balances to
secure coordination within the departments of the government.
An example of the Judiciary’s system of checks and balances is its power to examine and validate the acts
done by both executive and legislative departments. In technical terms, the power of judicial review.
RELEVANCE OF THIS CASE TO THE “POWERS OF JUDICIAL REVIEW”:
In case of conflict between the several departments and among its agencies, the judiciary is the only
constitutional mechanism devised to resolve conflicts and allocate constitutional boundaries.
SUPPORTING DETAILS:
Checks and Balances – ensures no one branch would be able to control too much power; basis of the
Separation of Powers.
Quasi-judicial – a judicial act performed by an official who is either not a judge or not acting in his or her
capacity as a judge; a proceeding conducted by an administrative or executive official that is similar to a court
proceeding.
National Assembly (NA) – served as the Legislative Department during the Commonwealth of the PH.
Passed laws that prepare the PH for its eventual independence.
Electoral Commission – (LT) an agency of the NA with authority over election related matters.

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