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
In the September 17, 1935 elections, Jose A. Angara and Pedro Ynsua were candidates for the National Assembly. Angara was proclaimed winner. On December 3, 1935, the National Assembly passed Resolution No. 8, confirming the election of members against whom no protest had been filed. On December 8, 1935, Ynsua filed an election protest with the Electoral Commission. Angara moved to dismiss, arguing the protest was filed out of time per the Assembly’s resolution. The Electoral Commission denied the motion, asserting its jurisdiction to hear the protest. Angara then filed this petition for prohibition with the Supreme Court to restrain the Electoral Commission from proceeding.
ISSUE
The primary issue is whether the Supreme Court has jurisdiction over the Electoral Commission and the power to review its decisions. Subsidiary issues involve determining which body—the National Assembly or the Electoral Commission—has the constitutional authority to regulate the filing period for election protests.
RULING
The Supreme Court dismissed the petition, upholding the Electoral Commission’s jurisdiction.
1. Judicial Power and Jurisdiction: The Court held it possesses the power and duty to determine the proper allocation of constitutional powers among departments of government. It has jurisdiction to review the Electoral Commission’s act in assuming to take cognizance of Ynsua’s protest to determine whether it was within its constitutional sphere.
2. Nature of the Electoral Commission: The Electoral Commission is a constitutional creation, separate from and independent of the National Assembly. It is not a mere tool of the legislature but a body with quasi-judicial functions to decide all contests relating to the election, returns, and qualifications of Assembly members.
3. Authority to Regulate Protest Periods: The power to prescribe periods for filing election protests is incidental to the Electoral Commission’s constitutional power to decide such contests. This regulatory power was not vested in the National Assembly. Therefore, Resolution No. 8 of the National Assembly could not limit the Commission’s jurisdiction or bar Ynsua’s protest.
4. Applicable Law: Under the transitory provisions of the Constitution, Section 478 of the Election Law remained operative. This law previously vested the separate houses of the legislature with authority to regulate the time for filing contests. By constitutional construction, this authority now pertains to the Electoral Commission. Its resolution of December 9, 1935, fixing the filing period, was valid.
5. Disposition: The Electoral Commission validly acquired jurisdiction over Ynsua’s protest, which was filed within the period it prescribed. The writ of prohibition was denied, and the Electoral Commission was to proceed with the protest.
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