Maui Ramos

JOSE ANGARA, petitioner, vs. THE ELECTORAL COMISSION, PEDRO YNSUA,

MIGUEL CASTILLO, and DIONISIO C. MAYOR, respondents
Laurel, J.
G.R. No. 45081. – July 15,1936
(Courts: Who interprets the Constitution and the Law?; Separation and Blending of Powers)

An original action for the issuance of a writ of prohibition to restrain and prohibit the Electoral
Commission from taking further cognizance of the protest filed by Pedro Ynsua against the
election of Jose Angara as a member of the National Assembly for the first assembly district of
Province of Tayabas.

FACTS
 In September 17, 1935, Angara, Ynsua, Castillo, and Mayor were canditates for the
position of member of the National Assembly, 1 st district of Tayabas. – Angara was
proclaimed as the winner on October 7, subsequently taking oath of office on Nov 15.
 Dec 3 – National Assembly (NA) passed Resolution No.8– confirming the election of NA
members who don’t have pending protests that have been filed against.
 Dec 8 – Ynsua filed before the Electoral commission (EC) a Motion of Protest against
Angara, praying: that he be declared winner, or the election of the position be nullified.
 Dec 9 – EC passed a resolution (Par. 6: The last day of the filing of protests against NA
members is today, which is Dec 9, 1935)
 Dec 20 – Angara filed a Motion to Dismiss the Protest, stating that Reso 8 was adopted in
legitimate exercise of the Constitutional prerogative to prescribe a period during which
protests may be filed.
 Dec 27 – Ynsua filed an Answer to the Motion of Dismissal alleging that there is no legal
or constitutional provision barring protests after the confirmation of election.
 Dec 31 – Angara filed a Reply to the Answer to the Motion of Dismissal.
 January 23, 1936 – EC denied Angara’s Motion to Dismiss the Protest
 The petition for a writ of prohibition against the EC is DENIED, with COSTS AGAINST
petitioner.

ISSUE/S
1. W/N the Supreme Court has jurisdiction over the case
2. W/N the EC acted without or in excess of its jurisdiction in assuming to take cognizance
of Ynsua’s protest (protest against an elected member despite NA’s confirmation)

HELD
1. The SC has jurisdiction.
a. Doctrines of Separation of Powers and Checks and Balances dictates the specific
powers of the branches of gov’t. The Judiciary holds the power to review acts
committed by other branches whether they conform to the constitution or not.
b. In the case, the NA confirmed the elections of members through Reso. 8.
However, the EC stated that the data of filing protests was Dec 9, later than the
NA’s confirmation.
c. Thus, whose constitutional power prevails over the other?
Maui Ramos

d. SC is in the opinion that they have jurisdiction over the case for the purpose of
determining the character, scope and extent of the Constitutional grant to the EC
as the sole judge of all contests relation to the lection, returns, and qualification of
Members of the NA.
2. EC did not act without or in excess of its Jurisdiction.
a. The EC was made to remedy certain evils of which the framers of the Constitution
were cognizant.
b. EC was made as an independent and impartial tribunal.
c. EC is a constitutional creation, authorized distinct functions assigned to it by the
constitution.
d. If we concede the power to the NA, the grant of power to the EC would be
ineffective.
RULING
The petition for a writ of prohibition against the Electoral Commission is DENIED, with COSTS
AGAINST petitioner.

The EC was acting within the legitimate exercise of its Constitutional prerogative.

CONCUR/DISSENT
Abad Santos, J., concurring

MODULE TOPIC 3: The Philippine Legal System

- Courts: Who interprets the Constitution and the law?
- Separation and Blending of Powers
o The Judiciary has power to review acts committed by other gov’t branches
whether they conform to the constitution or not.
o The NA and SC: whose constitutional power prevails over the other?
o The SC has jurisdiction over determining the character, scope and extent of a
constitutional grant.