Angara v. Electoral Commission Ponente: Laurel, J. Facts: 1.

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. 2. 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. 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 petitioners Motion to Dismiss the Protest. 4. The Petitioner now files a protest to the SC, questioning the jurisdiction of the ELECOM over the case, arguing that: 5. 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. 6. Res#8 is valid and should be respected, granted that NA is the only body that could regulate the proceedings of the ELECOM 7. 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 8. The Solicitor-General responded on behalf of ELECOM arguing that: 9. 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 exercise of quasijudicial functions. Said act is beyond cognizance or control of SC. 10. 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. 11. ELECOM is not an inferior tribunal, or corporation, or board, or person 12. Ynsua filed an anwer arguing that: 13. 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 14. Respondent filed protest before ELECOM ended the period for filing election complaints E2014 | Constitutional Law I | Prof. Alberto Muyot | 8

15. 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 ELECOMs jurisdiction 16. 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 17. 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 18. Par6,art7 of Tydings-McDuffie Law is not applicable Issue: 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. Angara v. Electoral Commission (Separation of Powers) Dealino, J.S. Facts: In the elections of 9/17/1935, the petitioner Jose A. Angara, as well as respondents Pedro Ynsua, Miguel Castillo, and Dionisio Mayor were candidates for the position of member of the National Assembly for the first district of the Province of Tayabas. On 10/7/1935, the petitioner was proclaimed member-elect. On 11/15/1935, the petitioner took his oath of office. On 12/3/1935, the National Assembly passed Resolution #8, which confirmed the election of members against whom no protest(s) had been filed at the time of its passage on 12/3/1935. On 12/8/1935, respondent Ynsua filed a Motion of Protest, praying, among other things, that the respondents election be nullified. On 12/9/1935, the Electoral Commission adopted a resolution, which provided that the Commission would not consider protests that have been presented on or after that day. On 12/20/1935, petitioner Angara filed a Motion to Dismiss the Protest. After subsequent replies between the two, the Commission, on 1/23/1936, denied the petitioners Motion to Dismiss the Protest. The case was argued before the Supreme Court on 3/13/1936. It was decided on 3/21/1936. Issues: Whether or not.. 1) the Supreme Court had jurisdiction over the Electoral Commission. (Negative raised by Ynsua and the EC against the petitioner), 2) if the SC had jurisdiction over the controversy over the protest filed. (Negative raised by petitioner against respondents), and 3) the EC acted without or in excess of its jurisdiction in taking cognizance of the protest despite the Resolution #8 by the NA. (Negative raised by Ynsua.)

Decision: Angara lost by having his petition for prohibition against the EC denied. Ratio Decidendi: 1+2) The SC had jurisdiction over the EC. The EC is a constitutional organ, created to determine all contests related to the elections, returns, and qualifications on the members of the National Assembly. Although it may not be interfered with, when and while acting within the limits of its authority, it is not beyond the reach of the Constitution and its restrictions. It is not a separate branch of government. In countries such as Poland or Austria, express provisions have been made by their respective constitutions, limiting the powers of courts in determining the constitutional issues. In countries such as Norway where the constitution is silent on the matter, courts have assumed this power. 3) The EC acted within its jurisdiction. According to Article VI Section 4 of the constitution of the time, 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. An examination of its history traces its evolution. At first, in 1902, the assembly was the judge of the elections, returns, and qualifications of its own members, modeled on the Constitution of the United States. The SC characterized the grant of power to both Houses as full, clear, and complete in Veloso v. Boards of Canvassers of Samar and Leyte (1919). On 8/30/1934, the Committee on Constitutional Guarantees of the Constitutional Conventions sub-committee recommended the creation of an entity empowered to hear protests against the election of members of the legislature and the executive (particularly those who needed the vote of the whole nation.) A similar report was submitted to the Committee on Legislative Power, reading The elections, returns, and qualifications of members of either house shall be judged by an Electoral Commission, constituted by 3 members elected by the party with the largest number of votes, 3 by the member of the party with the second-most number of votes, chaired by one Justice of the SC as designated by the CJ. The Sponsorship Committee modified the phraseology to suit a unicameral legislature. The final product resulted in Article VI Section 4. The experiences of England and the US showed that the development of the transfer of powers on the matter of membership from the legislature to an independent and impartial tribunal is not unique to the Philippines. Notes: Issues 1 and 2 deal with a separation of powers, among the three coequal branches of government, the SC bearing the burden of assessing the constitutionality of the acts of the other two branches. Issue 3 deals with the separation of powers within one branch of government, the SC being the final arbiter over such a situation, especially when the separation is due to the Constitution itself.