GR 45081; (July, 1936) (Digest)
G.R. No. 45081 ; July 15, 1936
JOSE A. ANGARA, petitioner, vs. THE ELECTORAL COMMISSION, PEDRO YNSUA, MIGUEL CASTILLO, and DIONISIO C. MAYOR, respondents.
FACTS
Petitioner Jose A. Angara and respondent Pedro Ynsua were candidates for the National Assembly. Angara was proclaimed winner. The National Assembly passed Resolution No. 8 on December 3, 1935, confirming the election of members against whom no protest had been filed before its adoption. On December 8, 1935, Ynsua filed an election protest with the Electoral Commission. The Electoral Commission, on December 9, 1935, adopted its own rule setting that date as the deadline for filing protests. Angara moved to dismiss the protest, arguing it was filed after the National Assembly’s deadline. The Electoral Commission denied his motion. Angara then filed this petition for prohibition with the Supreme Court to restrain the Electoral Commission from proceeding with the protest.
ISSUE
The main issue is whether the Supreme Court has jurisdiction over the Electoral Commission and the power to review its decisions or acts. Subsidiarily, which body—the National Assembly or the Electoral Commission—has the constitutional power to regulate the filing of election protests?
RULING
The Supreme Court ruled it has jurisdiction. The Court held that the judicial power granted by the Constitution includes the duty to determine the proper allocation of powers among coordinate departments of government. This case presented a justiciable controversy involving the interpretation of the Constitution regarding the powers of the Electoral Commission versus the National Assembly.
On the substantive issue, the Court ruled that the Electoral Commission is a constitutional body created as an independent tribunal to exercise sole and exclusive jurisdiction over all contests relating to the election, returns, and qualifications of members of the National Assembly. The power to regulate the filing of such contests is an essential and implied power necessary for the Electoral Commission to exercise its jurisdiction effectively. Therefore, the Electoral Commission’s resolution setting the deadline for protests prevails over the National Assembly’s Resolution No. 8. The National Assembly cannot deprive the Electoral Commission of its constitutional jurisdiction by its own confirmation resolution. The writ of prohibition was denied, and the Electoral Commission was held to have jurisdiction over Ynsua’s protest.
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