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Angara v. Electoral Commission, GR No.

L-45081 (15 July 1936)

63 Phil. 139 Political Law Judicial Review Electoral Commission
FACTS: In the elections of Sept 17, 1935, Angara, and the respondents, Pedro Ynsua et al. were
candidates voted for the position of member of the National Assembly for the first district of the Province
of Tayabas. On Oct 7, 1935, Angara was proclaimed as member-elect of the NA for the said district. On
November 15, 1935, he took his oath of office. On Dec 3, 1935, the NA in session assembled, passed
Resolution No. 8 confirming the election of the members of the National Assembly against whom no
protest had thus far been filed. On Dec 8, 1935, Ynsua, filed before the Electoral Commission a Motion
of Protest against the election of Angara. On Dec 9, 1935, the EC adopted a resolution, par. 6 of which
fixed said date as the last day for the filing of protests against the election, returns and qualifications of
members of the NA, notwithstanding the previous confirmation made by the NA. Angara filed a Motion to
Dismiss arguing that by virtue of the NA proclamation, Ynsua can no longer protest. Ynsua argued back
by claiming that EC proclamation governs and that the EC can take cognizance of the election protest
and that the EC cannot be subject to a writ of prohibition from the SC.

ISSUES: Whether or not the SC has jurisdiction over such matter.

Whether or not EC acted without or in excess of jurisdiction in taking cognizance of the election protest.

HELD: The SC ruled in favor of Angara. The SC emphasized that in cases of conflict between the several
departments and among the agencies thereof, the judiciary, with the SC as the final arbiter, is the only
constitutional mechanism devised finally to resolve the conflict and allocate constitutional boundaries.
That judicial supremacy is but the power of judicial review in actual and appropriate cases and
controversies, and is the power and duty to see that no one branch or agency of the government
transcends the Constitution, which is the source of all authority.
That the Electoral Commission is an independent constitutional creation with specific powers and
functions to execute and perform, closer for purposes of classification to the legislative than to any of the
other two departments of the government.
That the Electoral Commission is the sole judge of all contests relating to the election, returns and
qualifications of members of the National Assembly.