Angara v Electoral Commission

GR No. 45081
July 15, 1936

Petitioner: Jose A. Angara

Respondents: The Electoral Commission, Pedro Ynsua, Miguel Castillo, Dionisio C. Mayor
Nature of the Action: Original Action in the Supreme prohibition
Facts:

September 17, 1935. Angara and respondents were candidates voted for the position of
member of the National Assembly for the 1st district of the Province of Tayabas.
October 7, 1935. Angara was proclaimed and took his oath of office on November 15, 1935
December 3, 1935. National Assembly passed Resolution No. 8 confirming the election of those
who have not been subject of an election protest prior to the adoption of the said resolution.
December 8, 1935. Ynsua filed against the petitioner before the Electoral Commission a
"Motion of Protest" against the election of Angara.
December 9, 1935. The Electoral Commission adopted its own resolution providing it will not
consider any election protest that was not submitted on or before December 9, 1935.
Angara filed a "Motion to Dismiss", arguing that by virtue of the National Assembly
proclamation, Ynsua can no longer protest.
Ynsua argued back by claiming that the Electoral Commission proclamation governs and that
the Electoral Commission can take cognizance of the election protest and that Electoral
Commission cannot be subject to a writ of prohibition from the Supreme Court.

Issue:
Has the Supreme Court jurisdiction over the Electoral Commission and the subject matter of the
controversy upon the foregoing related facts and in the affirmative?
Has the said Electoral Commission acted without or in excess of its jurisdiction in assuming to
take cognizance of the protest filed against the election of the herein petitioner notwithstanding
the previous confirmation of such election by resolution of the National Assembly?
Held:

The Electoral Commission acted within the legitimate exercise of its constitutional prerogative in
assuming to take cognizance of the protest filed by the respondent Ynsua against the petitioner
Angara, and that the earlier resolution of the National Assembly cannot in any manner tell the
time for filing election protests against members of the National Assembly, nor prevent the filing
of a protest within such time as the rules of the Electoral Commission might prescribe.
The Supreme Court has jurisdiction over the Electoral Commission and the subject matter 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."

The petition for a writ of prohibition against the Electoral Commission is hereby denied.