Angara v Electoral Commission digest

ANGARA

V

ELECTORAL COMMISSION [63 PHIL. 139 1936]

Nature of the Case: Original Action to the SC. Petition for the issuance of a writ of prohibition to restrain and prohibit the ELECOM from taking further cognizance of the protest filed by Pedro Ynsua against the election of the petitioner as a member of the NA Facts of the Case: The new constitution for the Independent Philippine Commonwealth was just promulgated. The petitioner, Angara, ran for the position of representative of the First District of the Province of Tayabas to the NA Septmeber 17, 1935 against Ynsua (one of the respondents) and others. On October 7, he was proclaimed by the provincial board of canvassers as the candidate who won the most votes and thus the winner. He took his oath of office on Novermber 15 (the start of the Commonwealth) and was confirmed by the NA on December 3 as an uncontested member of the NA. Also on this day, Res#8 was passed by the NA, confirming the membership of nonprotested elections of members of the NA and, in effect, limiting the time for presentation of protests. However, there was the ELECOM, which was a constitutional body invested with the jurisdiction to decide “all cases relating to the election, returns, and qualifications of the members of the NA”, was just being formed on December 4 and 6 and just met for the first time on December 9, fixing that day as the last day for the filing of election protests. Ynsua filed his “Motion of Protest” to the ELECOM on December 8, a day before the said body ended the period for filing of election protest. After that, Angara filed a “Motion to Dismiss the Protest” to the ELECOM on the grounds that he was already confirmed a member of the NA through the Res#8 and through that resolution, the prescribed period for filing of protests had already ended on December 3, and the respondent was late in filing his protest because he filed the protest after December 3. Ynsua filed an “Answer to the Motion of Dismissal” arguing that there was no constitutional or legal provision which stated that members of the NA cannot be contested after confirmationof the NA. Angara replied to this “Answer” but the ELECOM promulgated a resolution denying the petitioner’s “Motion to Dismiss the Protest”. The Petitioner now files a protest to the SC, questioning the jurisdiction of the ELECOM over the case, arguing that:  the ELECOM has jurisdiction over the merits of contested elections to the NA but the NA has the power to regulate the proceedings of the NA, granted that ELECOM is part of the NA. ELECOM could only regulate its proceedings if the NA did not provide for it.  Res#8 is valid and should be respected, granted that NA is the only body that could regulate the proceedings of the ELECOM  Under Par13 of §1 of Ordinance appended to the Constitution and par6Art7 of the Tydings-McDuffie Law as well as §1 and 2 of art VIII of the Constitution, SC has jurisdiction to pass upon the fundamental questions raised in this issue because it involves the interpretation of the Constitution of the Philippines The Solicitor-General responded on behalf of ELECOM arguing that:  ELECOM is a constitutional body invested with the jurisdiction to decide “all contests relating to the election, returns, and qualification of the members of the NA” and that Dec 9 was the date fixed by ELECOM as the last day of filing for protest and its resolution dated January 23, 1936 was an act of its legitimate Codes: ELECOM (Election Commission); NA (National Assembly); Res#8 (Resolution No. 8); SC (Supreme Court)

exercise of quasi-judicial functions. Said act is beyond cognizance or control of SC.  Res#8 did and could not deprive ELECOM of its jurisdiction to take cognizance of election protests filed within the limit that the ELECOM would set.  ELECOM is not an “inferior tribunal, or corporation, or board, or person” Ynsua filed an anwer arguing that:  Res#8 did not limit his filing for protest for ELECOM fixed the deadline on Dec 9 and not on the passage of Res#8, which was on Dec3  Respondent filed protest before ELECOM ended the period for filing election complaints  ELECOM acquired jurisdiction over election protest and Jan 23 resolution of ELECOM denying the “Motion to Dismiss the Protest” was not reviewable by the SC by means of a writ of prohibition since it was part of ELECOM’s jurisdiction  No constitutional nor legal provision requires the confirmation of members of the NA and that the said confirmation could not limit the period for filing protest  ELECOM is an independent constitutional entity with quasi-judicial functions and thus, its decisions are final and unappealable; also ELECOM is a constitutional creation which is not an inferior tribunal, or corporation, board, or person and is not subject to a writ of prohibition from the SC  Par6,art7 of Tydings-McDuffie Law is not applicable Issues: 1. WON the SC has jurisdiction over the ELECOM and the subject matter of the controversy 2. WON, if ever the first is granted, ELECOM acted within or without its jurisdiction in assuming cognizance of the protest filed against the election of Angara Held & Ratio: 1. Yes. The SC has jurisdiction over the ELECOM: separation of powers granted by Consti (through separate articles for each branch) but check and balances maintain coordination among the branches. When there are conflicts between the boundaries of powers and functions of each branch, the Judiciary has the power to review and resolve these conflicts through Judicial Review (referred to as Judicial Supremacy). This however is limited to actual cases and controversies. 2. Yes. ELECOM acted within its jurisdiction since ELECOM is recognized as an independent quasi-judicial body which is not an inferior tribunal, or corporation, board, or person, and is granted the powers to be the sole judge of all contests relating to the election, returns and qualifications of members of the NA. The present constitution granted the ELECOM with all the powers exercised by the legislature relating to the said function of ELECOM, and this includes the regulation of the rules and procedures of election protests. The confirmation of NA of its members is not required and does not limit the ELECOM of its power to fix dates for election protest, or else this would undermine the power and functions of the ELECOM. DECI: petition for writ of prohibition denied, with costs against the petitioner.

Codes: ELECOM (Election Commission); NA (National Assembly); Res#8 (Resolution No. 8); SC (Supreme Court)

Codes: ELECOM (Election Commission); NA (National Assembly); Res#8 (Resolution No. 8); SC (Supreme Court)