Angara vs Electoral Commission Case Digest – G.R. No. L- district of Tayabas. On Oct.

7, 1935, the provincial board of canvassers

45081 July 15, 1936 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
FACTS
passed Resolution No. 8, which in effect, fixed the last date to file election
Ynsua, a candidate vying for the Angara’s position filed his election protest
protests. On Dec. 8, 1935, Ynsua filed before the Electoral Commission a
before the Electoral Commission. Angara sought to prohibit the Electoral
"Motion of Protest" against Angara and praying, among other things, that
Commission from taking further cognizance of the Ynsua’s motion.
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
Angara argues, “the constitution excludes from the COmmission’s jurisdiction
Commission adopted a resolution (No. 6) stating that last day for filing of
the power to regulate the proceedings of such election contests. Moreover, the
protests is on Dec. 9. Angara contended that the Constitution confers
Commission can regulate the proceedings of election protests only if the
exclusive jurisdiction upon the Electoral Commission solely as regards the
National Assembly has not availed of its primary power to regulate such
merits of contested elections to the National Assembly and the Supreme Court
proceedings.
therefore has no jurisdiction to hear the case.
Issue
Does the Electoral Commission have the power to promulgate rules
DECISION: Dismissed
notwithstanding the resolution of the National Assembly?
RATIO DECIDENDI: In this case, the nature of the present controversy shows
Ruling
the necessity of a final constitutional arbiter to determine the conflict of
Yes.
authority between two agencies created by the Constitution. The court has
jurisdiction over the Electoral Commission and the subject matter of the
The purpose of the creation of the Electoral Commission was to transfer in its
present controversy for the purpose of determining the character, scope and
totality all the powers previously exercised by the Legislature in matters
extent of the constitutional grant to the Electoral Commission as "the sole
pertaining to contested elections of its members, to an independent and
judge of all contests relating to the election, returns and qualifications of the
impartial tribunal.
members of the National Assembly." (Sec 4 Art. VI 1935 Constitution). It is
held, therefore, that the Electoral Commission was acting within the legitimate
The petition for a writ of prohibition against the Electoral Commission is hereby
exercise of its constitutional prerogative in assuming to take cognizance of the
denied, with costs against the petitioner. So ordered.
election protest filed by Ynsua.
Angara vs. Electoral Commission, 63 Phil 139 (1936)
6/13/2020
ANGARA VS ELECTORAL COMMISSION GR NO. L-45081, July
0 COMMENTS 15, 1936
Doctrine: The separation of powers is a fundamental principle in our system of
government. It obtains not through express provision but by actual division in
ISSUE: Whether or not The Electoral Commission has acted without or in our Constitution. Each department of the government has exclusive
excess of its jurisdiction. cognizance of matters within its jurisdiction, and is supreme within its own
sphere. But it does not follow from the fact that the three powers are to be kept
FACTS: In the elections of Sept. 17, 1935, petitioner Jose A. Angara and the separate and distinct that the Constitution intended them to be absolutely
respondents Pedro Ynsua, Miguel Castillo, and Dionisio Mayor were unrestrained and independent of each other. The Constitution has provided for
candidates for the position of members of the National Assembly for the first
an elaborate system of check and balances to secure coordination in the
workings of the various departments of the government.
FACTS:
In the elections of September 17, 1935, the petitioner, Jose A. Angara, and the
respondents, Pedro Ynsua, Miguel Castillo and Dionisio Mayor,were
candidates voted for the position of member of the National Assembly for the
first district of the Province of Tayabas. The provincial board of canvassers,
proclaimed the petitioner as member-elect of the National Assembly for the
said district, for having received the most number of votes. On November 15,
1935, the petitioner took his oath of office. Respondent Pedro Ynsua filed
before the Electoral Commission a “Motion of Protest” against the election of
the herein petitioner, Jose A. Angara, and praying, among other-things, that
said respondent be declared elected member of the National Assembly for the
first district of Tayabas, or that the election of said position be nullified/
Petitioner Jose A. Angara, one of the respondents in the aforesaid protest,
filed before the Electoral Commission a “Motion to Dismiss the Protest”,
alleging (a) that Resolution No. 8 of the National Assembly was adopted in the and even if it were, conflicting claims of authority under the fundamental law
legitimate exercise of its constitutional prerogative to prescribe the period
during which protests against the election of its members should be presented; determined by the judiciary in justifiable and appropriate cases.
(b) that the aforesaid resolution has for its object, and is the accepted formula
for, the limitation of said period; and (c) that the protest in question was filed In our case, the nature of the present controversy shows the necessity of a
out of the prescribed period
Respondent Pedro Ynsua, filed an “Answer to the Motion of Dismissal”
alleging 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 promulgated a resolution on January 23, 1936,
denying herein petitioner’s “Motion to Dismiss the Protest.
ISSUE:
1. WON the Supreme Court has jurisdiction over the Electoral Commission
and the subject matter of the controversy upon the foregoing related facts, and
if in the affirmative
2. WON the said Electoral Commission acted without or in excess of its
jurisdiction in assuming to the cognizance of the protest filed the election of
the herein petitioner notwithstanding the previous confirmation of such election
by resolution of the National Assembly
RULING:
1. Yes. The Electoral Commission, as we shall have occasion to refer
hereafter, is a constitutional organ, created for a specific purpose, namely to
determine all contests relating to the election, returns and qualifications of the
members of the National Assembly. Although the Electoral Commission may
not be interfered with, when and while acting within the limits of its authority, it
does not follow that it is beyond the reach of the constitutional mechanism
adopted by the people and that it is not subject to constitutional restrictions.
The Electoral Commission is not a separate department of the government,
between department powers and agencies of the government are necessarily
final constitutional arbiter to determine the conflict of authority between two
agencies created by the Constitution. Were we to decline to take cognizance
of the controversy, who will determine the conflict? And if the conflict were left
undecided and undetermined, would not a void be thus created in our
constitutional system which may be in the long run prove destructive of the
entire framework? To ask these questions is to answer them. Natura vacuum
abhorret, so must we avoid exhaustion in our constitutional system. Upon
principle, reason and authority, we are clearly of the opinion that upon the
admitted facts of the present case, this court has jurisdiction over the Electoral
Commission and the subject mater 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. No. The issue hinges on the interpretation of section 4 of Article VI of the the power of the commission to lay down the period within which protests
Constitution which provides: should be filed, the grant of power to the commission would be ineffective. The
Electoral Commission in such case would be invested with the power to
“SEC. 4. There shall be an Electoral Commission composed of three Justice of determine contested cases involving the election, returns and qualifications of
the Supreme Court designated by the Chief Justice, and of six Members the members of the National Assembly but subject at all times to the regulative
chosen by the National Assembly, three of whom shall be nominated by the power of the National Assembly. Not only would the purpose of the framers of
party having the largest number of votes, and three by the party having the our Constitution of totally transferring this authority from the legislative body be
second largest number of votes therein. The senior Justice in the Commission frustrated, but a dual authority would be created with the resultant inevitable
shall be its Chairman. The Electoral Commission shall be the sole judge of all clash of powers from time to time. A sad spectacle would then be presented of
contests relating to the election, returns and qualifications of the members of the Electoral Commission retaining the bare authority of taking cognizance of
the National Assembly.” cases referred to, but in reality without the necessary means to render that
authority effective whenever and whenever the National Assembly has chosen
From the deliberations of our Constitutional Convention it is evident that the to act, a situation worse than that intended to be remedied by the framers of
purpose was to transfer in its totality all the powers previously exercised by the our Constitution. The power to regulate on the part of the National Assembly in
legislature in matters pertaining to contested elections of its members, to an procedural matters will inevitably lead to the ultimate control by the Assembly
independent and impartial tribunal. It was not so much the knowledge and of the entire proceedings of the Electoral Commission, and, by indirection, to
appreciation of contemporary constitutional precedents, however, as the long- the entire abrogation of the constitutional grant. It is obvious that this result
felt need of determining legislative contests devoid of partisan considerations should not be permitted.
which prompted the people, acting through their delegates to the Convention,
to provide for this body known as the Electoral Commission. With this end in It is, indeed, possible that, as suggested by counsel for the petitioner, the
view, a composite body in which both the majority and minority parties are Electoral Commission may abuse its regulatory authority by admitting protests
equally represented to off-set partisan influence in its deliberations was beyond any reasonable time, to the disturbance of the tranquillity and peace of
created, and further endowed with judicial temper by including in its mind of the members of the National Assembly. But the possibility of abuse is
membership three justices of the Supreme Court. not argument against the concession of the power as there is no power that is
not susceptible of abuse. In the second place, if any mistake has been
The Electoral Commission is a constitutional creation, invested with the committed in the creation of an Electoral Commission and in investing it with
necessary authority in the performance and execution of the limited and exclusive jurisdiction in all cases relating to the election, returns, and
specific function assigned to it by the Constitution. Although it is not a power in qualifications of members of the National Assembly, the remedy is political, not
our tripartite scheme of government, it is, to all intents and purposes, when judicial, and must be sought through the ordinary processes of democracy. All
acting within the limits of its authority, an independent organ. It is, to be sure, the possible abuses of the government are not intended to be corrected by the
closer to the legislative department than to any other. The location of the judiciary. We believe, however, that the people in creating the Electoral
provision (section 4) creating the Electoral Commission under Article VI Commission reposed as much confidence in this body in the exclusive
entitled “Legislative Department” of our Constitution is very indicative. Its determination of the specified cases assigned to it, as they have given to the
compositions is also significant in that it is constituted by a majority of Supreme Court in the proper cases entrusted to it for decision. All the
members of the legislature. But it is a body separate from and independent of agencies of the government were designed by the Constitution to achieve
the legislature. specific purposes, and each constitutional organ working within its own
particular sphere of discretionary action must be deemed to be animated with
If we concede the power claimed in behalf of the National Assembly that said the same zeal and honesty in accomplishing the great ends for which they
body may regulate the proceedings of the Electoral Commission and cut off were created by the sovereign will. That the actuations of these constitutional
agencies might leave much to be desired in given instances, is inherent in the
perfection of human institutions. In the third place, from the fact that the
Electoral Commission may not be interfered with in the exercise of its
legitimate power, it does not follow that its acts, however illegal or
unconstitutional, may not be challenge in appropriate cases over which the
courts may exercise jurisdiction.
In view of the conclusion reached by us relative to the character of the
Electoral Commission as a constitutional creation and as to the scope and
extent of its authority under the facts of the present controversy, we deem it
unnecessary to determine whether the Electoral Commission is an inferior
tribunal, corporation, board or person within the purview of sections 226 and
516 of the Code of Civil Procedure.

From another angle, Resolution No. 8 of the National Assembly confirming the The petition for a writ of prohibition against the Electoral Commission is hereby
election of members against whom no protests had been filed at the time of its denied, with costs against the petitioner. So ordered.
passage on December 3, 1935, can not be construed as a limitation upon the
time for the initiation of election contests. While there might have been good Angara vs Electoral Commission (G.R. No. L-45081)
reason for the legislative practice of confirmation of the election of members of Posted: July 25, 2011 in Case Digests
the legislature at the time when the power to decide election contests was still
0
lodged in the legislature, confirmation alone by the legislature cannot be
Separation of Powers
construed as depriving the Electoral Commission of the authority incidental to
its constitutional power to be “the sole judge of all contest relating to the
FACTS: In the elections of September 1935, Jose Angara, Pedro Ynsua,
election, returns, and qualifications of the members of the National Assembly”,
Miguel Castillo and Dionisio Mayor were candidates voted for the position of
to fix the time for the filing of said election protests. Confirmation by the
member of the National Assembly in the first district of Tayabas. The petitioner
National Assembly of the returns of its members against whose election no
was proclaimed member-elect for the said district for receiving the most
protests have been filed is, to all legal purposes, unnecessary. As contended
number of votes and thereafter took his oath in office. A Motion of Protest was
by the Electoral Commission in its resolution of January 23, 1936, overruling
filed by Ynsua against the election of the petitioner. The petitioner countered
the motion of the herein petitioner to dismiss the protest filed by the
this with a Motion to Dismiss the Protest which was denied by the Electoral
respondent Pedro Ynsua, confirmation of the election of any member is not
Commission.
required by the Constitution before he can discharge his duties as such
member. As a matter of fact, certification by the proper provincial board of
ISSUES: Whether the Supreme Court has jurisdiction over the Electoral
canvassers is sufficient to entitle a member-elect to a seat in the national
Commission and the subject matter of the controversy; and
Assembly and to render him eligible to any office in said body (No. 1, par. 1,
Rules of the National Assembly, adopted December 6, 1935).
Whether the said Electoral Commission acted without or in excess of its
jurisdiction in assuming cognizance of the protest filed over the election of
We hold, therefore, that the Electoral Commission was acting within the
herein petitioner.
legitimate exercise of its constitutional prerogative in assuming to take
cognizance of the protest filed by the respondent Pedro Ynsua against the
HELD: The National Assembly operates as a check on the Executive in the
election of the herein petitioner Jose A. Angara, and that the resolution of the
sense that its consent through its Commission on Appointments is necessary
National Assembly of December 3, 1935 can not in any manner toll the time
in the appointments of certain officers; and the concurrence of a majority of all
for filing protests against the elections, returns and qualifications of members
its members is essential to the conclusion of treaties. Furthermore, its power
of the National Assembly, nor prevent the filing of a protest within such time as
to determine what courts other than the Supreme Court shall be established,
the rules of the Electoral Commission might prescribe.
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 excess of its jurisdiction. RULING: In this case, the nature of the present
the other departments in the exercise of its power to determine the law, and controversy shows the necessity of a final constitutional arbiter to determine
hence to declare executive and legislative acts void if violative of the the conflict of authority between two agencies created by the Constitution. The
Constitution. This power of has been stated in Section 2, Article VIII of the court has jurisdiction over the Electoral Commission and the subject matter of
Constitution. the present controversy for the purpose of determining the character, scope
and extent of the constitutional grant to the Electoral Commission as "the sole
Section 4, Article VI of the Constitution provides that “x x x The Electoral judge of all contests relating to the election, returns and qualifications of the
Commission shall be the sole judge of all contests relating to the election, members of the National Assembly." (Sec 4 Art. VI 1935 Constitution). It is
returns and qualifications of the members of the National Assembly.” In view of held, therefore, that the Electoral Commission was acting within the legitimate
the deliberations of the framers of the Constitution, it is held that the Electoral exercise of its constitutional prerogative in assuming to take cognizance of the
Commission was acting within the legitimate exercise of its constitutional election protest filed by Ynsua.
prerogative in assuming to take cognizance of the protest filed by the
respondent Ynsua. The petition of writ of prohibition against the Electoral Angara vs Electoral Commission Case Digest – G.R. No. L-
Commission is hereby denied. 45081 July 15, 1936 July 18, 2021 Angara vs Electoral
Commission Case Digest
ANGARA VS ELECTORAL COMMISSION Posted by kaye lee on
3:28 PM G.R. No. L-45081 July 15 1936 FACTS Ynsua, a candidate vying for the Angara’s position filed his election
protest before the Electoral Commission. Angara sought to prohibit the
FACTS: Jose Angara and Pedro Ynsua, Miguel Castillo and Dionisio Mayor Electoral Commission from taking further cognizance of the Ynsua’s motion.
were candidates voted for the position of member of the National Assembly for Angara argues, “the constitution excludes from the COmmission’s jurisdiction
the 1st district of Tayabas province. On Oct 17 1935, the provincial board of the power to regulate the proceedings of such election contests. Moreover, the
canvassers proclaimed Angara as member-elect of the Nat'l Assembly for Commission can regulate the proceedings of election protests only if the
garnering the most number of votes. He then took his oath of office on Nov National Assembly has not availed of its primary power to regulate such
15th. On Dec 3rd, Nat'l Assembly passed Res. No 8 which declared with proceedings.
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 Issue Does the Electoral Commission have the power to promulgate rules
declared elected member of the Nat'l Assembly. Electoral Commission passed notwithstanding the resolution of the National Assembly? Ruling Yes. The
a resolution in Dec 9th as the last day for the filing of the protests against the purpose of the creation of the Electoral Commission was to transfer in its
election, returns and qualifications of the members of the National Assembly. totality all the powers previously exercised by the Legislature in matters
On Dec 20, Angara filed before the Elec. Commission a motion to dismiss the pertaining to contested elections of its members, to an independent and
protest that the protest in question was filed out of the prescribed period. The impartial tribunal. The petition for a writ of prohibition against the Electoral
Elec. Commission denied Angara's petition. Angara prayed for the issuance of Commission is hereby denied, with costs against the petitioner. So ordered.
writ of prohibition to restrain and prohibit the Electoral Commission taking We hold, therefore, that the Electoral Commission was acting within the
further cognizance of Ynsua's protest. He contended that the Constitution legitimate exercise of its constitutional prerogative in assuming to take
confers exclusive jurisdiction upon the said Electoral Commissions as regards cognizance of the protest filed by the respondent Pedro Ynsua against the
the merits of contested elections to the Nat'l Assembly and the Supreme Court election of the herein petitioner Jose A. Angara, and that the resolution of the
therefore has no jurisdiction to hear the case. ISSUE: Whether or not the SC National Assembly of December 3, 1935 can not in any manner toll the time
has jurisdiction over the Electoral Commission and the subject matter of the for filing protests against the elections, returns and qualifications of members
controversy; Whether or not The Electoral Commission has acted without or in
of the National Assembly, nor prevent the filing of a protest within such time as Whether or not the Electoral Commission acted without or in excess of its
the rules of the Electoral Commission might prescribe. In view of the jurisdiction in taking cognizance of the protest filed against the election ofthe
conclusion reached by us relative to the character of the Electoral Commission petitioner notwithstanding the previous confirmation of such election
as a constitutional creation and as to the scope and extent of its authority byresolution of the National Assembly.
under the facts of the present controversy, we deem it unnecessary to RULING
determine whether the Electoral Commission is an inferior tribunal, 1.
corporation, board or person within the purview of sections 226 and 516 of the
Code of Civil Procedure. No, the Electoral Commission was acting within the legitimate exercise of
itsconstitutional prerogative in assuming to take cognizance of the protest filed
byPedro Ynsua against the election of Jose A. Angara, and that the resolution
ANGARA v. ELECOMG. R. No. L-45081 July 15, 1936 ofthe National Assembly of December 3, 1935 cannot in any manner toll the
timefor filing protests against the elections, returns and qualifications of
LAUREL, J.: members ofthe National Assembly, nor prevent the filing of a protest within
FACTS such time as therules of the Electoral Commission might prescribe.The
On October 7, 1935, the provincial board of canvassers, proclaimed Electoral Commission is a constitutional creation, invested with thenecessary
JoseAngara as member-elect of the National Assembly for the district of authority in the performance and execution of the limited andspecific function
Tayabas. OnDecember 8, 1935, Pedro Ynsua filed before the Electoral assigned to it by the Constitution. The grant of power to theElectoral
Commission a "Motion ofProtest" against the election of Angara, being the Commission to judge all contests relating to the election, returns
only protest filed after theconfirmation of elections, and praying, that he be andqualifications of members of the National Assembly, is intended to be
declared elected member of theNational Assembly for the first district of ascomplete and unimpaired as if it had remained originally in the
Tayabas, or that the election of said position benullified. The next day, the legislature.Moreover, the creation of the Electoral Commission carried with it
Electoral Commission adopted a resolution providing that itwill not consider ex necesitaterei the power regulative in character to limit the time with which
any election protest that was not submitted on or before December 9,1935. On protestsentrusted to its cognizance should be filed.
December 20, 1935, Angara, one of the respondents in the aforesaid
protest,filed before the Electoral Commission a
"Motion to Dismiss the Protest”. O
n December27, 1935, Ynsua, filed an "Answer to the Motion of Dismissal"
alleging that there is nolegal or constitutional provision barring the
presentation of a protest against theelection of a member of the National
Assembly after confirmation. Angara, filed a"Reply" to the aforesaid "Answer
to the Motion of Dismissal" on December 31, 1935.Finally, the case being
submitted for decision, the Electoral Commission promulgated aresolution on
January 23, 1936, denying
Angara’s
"Motion to Dismiss the Protest."
ISSUES
1.