G.R. No. L-45081 July 15 1936
FACTS:
Jose Angara and Pedro Ynsua, Miguel Castillo and Dionisio
Mayor were candidates voted for the position of member of the National Assembly
for the 1st district of Tayabas province.
On Oct 17 1935, the provincial board of canvassers
proclaimed Angara as member-elect of the Nat'l Assembly for garnering the most
number of votes. He then took his oath of office on Nov 15th. On Dec 3rd, Nat'l
Assembly passed Res. No 8 which declared with finality the victory of Angara. On
Dec 8, Ynsua filed before the Electoral Commission a motion of protest against
the election of Angara, that he be declared elected member of the Nat'l
Assembly. Electoral Commission passed a resolution in Dec 9th as the last day
for the filing of the protests against the election, returns and qualifications
of the members of the National Assembly. On Dec 20, Angara filed before the
Elec. Commission a motion to dismiss the protest that the protest in question
was filed out of the prescribed period. The Elec. Commission denied Angara's
petition.
Angara prayed for the issuance of writ of prohibition to
restrain and prohibit the Electoral Commission taking further cognizance of
Ynsua's protest. He contended that the Constitution confers exclusive
jurisdiction upon the said Electoral Commissions as regards the merits of
contested elections to the Nat'l Assembly and the Supreme Court therefore has
no jurisdiction to hear the case.
ISSUE:
Whether or not the SC has jurisdiction over the Electoral
Commission and the subject matter of the controversy;
Whether or not The Electoral Commission has acted without or in excess
of its jurisdiction.
RULING:
In this case, the nature of the present controversy shows
the necessity of a final constitutional arbiter to determine the conflict of
authority between two agencies created by the Constitution. 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." (Sec 4 Art. VI 1935 Constitution).
It is held, therefore, that the Electoral Commission was acting within the
legitimate exercise of its constitutional prerogative in assuming to take
cognizance of the election protest filed by Ynsua.
