Case Digest: Jose A. Angara vs. The Electoral Commission, et. al.

FACTS:

In the elections of September 1935, Jose Angara, Pedro Ynsua, Miguel Castillo and Dionisio Mayor were candidates voted for the position of member of the National Assembly in the first district of Tayabas.  The petitioner was proclaimed member-elect for the said district for receiving the most number of votes and thereafter took his oath in office.  A Motion of Protest was filed by Ynsua against the election of the petitioner.  The petitioner countered this with a Motion to Dismiss the Protest which was denied by the Electoral Commission.

ISSUES:

1. Whether the Supreme Court has jurisdiction over the Electoral Commission and the subject matter of the controversy; and
2. Whether the said Electoral Commission acted without or in excess of its jurisdiction in assuming cognizance of the protest filed over the election of herein petitioner.

RULING:

1. The National Assembly operates as a check on the Executive in the sense that its consent through its Commission on Appointments is necessary in the appointments of certain officers; and the concurrence of a majority of all its members is essential to the conclusion of treaties.  Furthermore, its power to determine what courts other than the Supreme Court shall be established, 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 the other departments in the exercise of its power to determine the law, and hence to declare executive and legislative acts void if violative of the Constitution.  This power of has been stated in Section 2, Article VIII of the Constitution.
2. Section 4, Article VI of the Constitution provides that “x x x The Electoral Commission shall be the sole judge of all contests relating to the election, returns and qualifications of the members of the National Assembly.” In view of the deliberations of the framers of the Constitution, it is held that the Electoral Commission was acting within the legitimate exercise of its constitutional prerogative in assuming to take cognizance of the protest filed by the respondent Ynsua.  The petition of writ of prohibition against the Electoral Commission is hereby denied.