Angara vs. Electoral Commission Digested

Angara vs. Electoral Commission 63 Phil 139

DOCTRINE OF SUPREMACY OF THE CONSTITUTION

FACTS:

In the elections of Sept. 17, 1935, petitioner Jose A. Angara and the respondents Pedro Ynsua, Miguel Castillo, and Dionisio Mayor were candidates for the position of members of the National Assembly for the first district of Tayabas.

On Oct. 7, 1935, the provincial board of canvassers proclaimed Angara as member-elect of the National Assembly and on Nov. 15, 1935, he took his oath of office.

On Dec. 3, 1935, the National Assembly passed Resolution No. 8, which in effect, fixed the last date to file election protests.

On Dec. 8, 1935, Ynsua filed before the Electoral Commission a "Motion of Protest" against Angara and praying, among other things, that Ynsua be named/declared elected Member of the National Assembly or that the election of said position be nullified.

On Dec. 9, 1935, the Electoral Commission adopted a resolution (No. 6) stating that last day for filing of protests is on Dec. 9.  Angara contended that the Constitution confers exclusive jurisdiction upon the Electoral Commission solely as regards the merits of contested elections to the National Assembly and the Supreme Court therefore has no jurisdiction to hear the case. 

    ISSUES:

Whether or not the Supreme Court has jurisdiction over the Electoral Commission and the subject matter of the controversy upon the foregoing related facts, and in the affirmative,

RULING:

In the case at bar, here is then presented an actual controversy involving as it does a conflict of a grave constitutional nature between the National Assembly on one hand, and the Electoral Commission on the other. Although the Electoral Commission may not be interfered with, when and while acting within the limits of its authority, it does not follow that it is beyond the reach of the constitutional mechanism adopted by the people and that it is not subject to constitutional restrictions. The Electoral Commission is not a separate department of the government, and even if it were, conflicting claims of authority under the fundamental law between departmental powers and agencies of the government are necessarily determined by the judiciary in justiciable and appropriate cases.

The court has jurisdiction over the Electoral Commission and the subject matter of the present controversy for the purpose of determining the character, scope, and extent of the constitutional grant to the Electoral Commission as "the sole judge of all contests relating to the election, returns, and qualifications of the members of the National Assembly."

The Electoral Commission was created to transfer in its totality all the powers previously exercised by the legislature in matters pertaining to contested elections of its members, to an independent and impartial tribunal. The express lodging of that power in the Electoral Commission is an implied denial in the exercise of that power by the National Assembly. And thus, it is as effective a restriction upon the legislative power as an express prohibition in the Constitution.

Therefore, the incidental power to promulgate such rules necessary for the proper exercise of its exclusive power to judge all contests relating to the election, returns, and qualifications of members of the National Assembly, must be deemed by necessary implication to have been lodged also in the Electoral Commission.

It appears that on Dec. 9, 1935, the Electoral Commission met for the first time and approved a resolution fixing said date as the last day for the filing of election protests. When, therefore, the National Assembly passed its resolution of Dec. 3, 1935, confirming the election of the petitioner to the National Assembly, the Electoral Commission had not yet met; neither does it appear that said body had actually been organized.

While there might have been good reason for the legislative practice of confirmation of the election of members of the legislature at the time the power to decide election contests was still lodged in the legislature, confirmation alone by the legislature cannot be construed as depriving the Electoral Commission of the authority incidental to its constitutional power to be "the sole judge of all contests...", to fix the time for the filing of said election protests.

The Electoral Commission was acting within the legitimate exercise of its constitutional prerogative in assuming to take cognizance of the protest filed by the respondent, Pedro Ynsua against the election of the herein petitioner, Jose A. Angara, and that the resolution of the National Assembly on Dec. 3, 1935, cannot in any manner toll the time for filing protest against the election, returns, and qualifications of the members of the National Assembly, nor prevent the filing of protests within such time as the rules of the Electoral Commission might prescribe.

The petition for a writ of prohibition against the electoral commission is hereby denied, with cost against the petitioner.