Angara vs.
Electoral Commission (1936)
SUMMARY: Judiciary established judicial authority and review; and set up basic interpretation of
Constitutional powers based on the EC’s scope in election contests
PETITIONER: Jose Angara – proclaimed winner as member of National Assembly (NA) for Tayabas
Province
RESPONDENT: Electoral Commission (EC) who received the protest of Pedro Ynsua, a competitor of
Angara, after the latter was declared winner
FACTS:
On 7 Oct 1935, Angara was proclaimed winner by the Board of Canvassers for having the most
number of votes. On 03 Dec, NA passed Reso 8, which confirmed the membership of the
members who did not receive an election protest.
On 8 Dec 1935, Ynsua filed a “Motion of Protest” before the EC, praying the he be declared
elected; which was accommodated by the EC by declaring 09 Dec to be the last day of filing.
Angara contends by filing writ of prohibition to restrain the EC from taking further cognizance of
Ynsua’s protest and subsequently a “Motion to dismiss Protest”, which claims that:
o Constitution only gives exclusive jurisdiction to the EC on merits of contested elections, and
excludes the power to regulate such. Regulation is the power of the NA.
ISSUES:
Whether or not the Court has jurisdiction to review the rulings of the Electoral Commission
organized under the National Assembly (YES)
Whether the Electoral Commission has jurisdiction over regulation of contested elections (YES)
HELD:
Writ of prohibition against the Electoral Commission is denied. In cases of conflict between several
departments and among the agencies, the judiciary is the only constitutional mechanism devised
to resolve the conflict and allocate constitutional boundaries. The 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.
The grant of power to the Electoral Commission to judge all contests relating to the
election, returns and qualifications of members of the National Assembly, is intended to be
as complete and unimpaired as if it had remained originally in the legislature. The express
lodging of that power in the Electoral Commission is an implied denial of the exercise of that power
by the National Assembly. And this is as effective a restriction upon the legislative power as an
express prohibition in the Constitution. If the Court concede to the power claimed of the National
Assembly and cut off the power of the commission to lay down the period to file protests, the grant
of power to the commission would be ineffective.
