Angara v. Electoral Commission, 63 Phil.

134 (1936)

Facts. Angara and Ynsua were rival in an electoral post in Tayabas 1 st District. After the
election, on Dec. 3 1935, the National Assembly proclaimed Angara as the winner. Ynsua
filed a Motion of Protest. On Dec. 9, 1935, the Electoral Commission issued a resolution
stating that the last day of filing electoral protests is Dec. 9, 1935.

With Ynsua’s protest within the prescribed date, the Electoral Commission recognized
Ynsua’ protest. Angara filed a Motion to Dismiss the Protest on account that the National
Assembly has already proclaimed him the winner last Dec. 3. This proclamation, he claims,
should nullify the Electoral Commission’s due date for filing. The Electoral Commission
denied Angara’s Motion to Dismiss.

Angara appealed in present court.

Issue. Does the Electoral Commissions’ act constitute grave abuse of discretion? -No

Ratio. It as within the Electoral Commission’s power to decide on the Angara-Ynsua issue.
The Constitution provides that the Electoral Commission shall be the sole judge of contests
pertaining to elections, returns, and qualifications of its members. That said, even if the
National Assembly has already proclaimed Angara as the representative of Tayabas
1st District, Electoral Commissions’ later resolution setting the due date for filing of protests
shall prevail. The Electoral Commission’s recognition of Ynsua’s electoral protest is valid.
Therefore, Angara’s writ for prohibition is denied.