Case Digest No.

8
Jose A. Angara vs. The Electoral Commission, Pedro Ynsua,
Miguel Castillo, and Dionisio C. Mayor
G.R. No. L-45081, July 15, 1936

In the national elections of September 1935, Jose Angara defeated Pedro Ynsua by
becoming a member of the First National District Assembly in Tayabas province. In
November 1935, Angara was sworn in.

On December 3, 1935, the National Assembly approved Resolution No. 8, which stated
that there were no further objections to the election, return, and qualification of its
members.
On December 8, 1935, Ynsua presented his objection to Angara's election to the
Electoral Commission.
On December 18, 1334, the Electoral Commission issued a decision that the last day to
protest the elections, return and verify the qualifications of the representatives of the
National Assembly was December 18, 1335. Angara denied that the National Assembly
had issued a resolution prohibiting protests after 3 December 1935 and submitted a
motion to dismiss Ynsua's protests.

Ynsua argued that his protests must be recognized because the Electoral Commission
is the body established by the constitution to settle disputes related to the election of
members of the National Assembly. The Electoral Commission agreed with Ynsua and
his protest was timely filed. The Angara is now questioning the merits of the
commission's actions by setting a deadline for filing complaints with the Supreme Court.

ISSUES:
1. Whether or not the Supreme Court may review the acts of the Electoral Commission;
and
2. Whether or not the Electoral Commission acted without or in excess of jurisdiction in
fixing the last date of filing protests despite the fact that the National Assembly fixed an
earlier date.

Decisions:
1. Yes, the SC emphasized that in cases of conflict between the several departments
and among the agencies of the government, the judiciary, with the SC as the final
arbiter, is the only constitutional mechanism devised finally to resolve the conflict and
allocate constitutional boundaries.
That judicial supremacy is but the power of judicial review in actual and appropriate
cases and controversies and is the power and duty to see that no branch, or agency of
the government transcends the Constitution, which is the source of all authority. The
Electoral Commission should be an independent constitutional creation that exercises
and performs certain powers and functions closer to the legislature than either of the
other two branches of government. The Electoral Commission is the sole judge of all
disputes relating to the election, re-election, and qualification of members of the
National Assembly. However, this does not mean that it exceeds the powers of the
Supreme Court.

2. No, the authorization of the Electoral Commission to settle all disputes relating to the
election, re-election, and qualification of members of the National Assembly is intended
to be full and complete. Parliament cannot anticipate or fetter these powers by setting
deadlines. Otherwise, the assignment of authority to the Electoral Commission will be
null and void. In such cases, the Electoral Commission shall have the power to decide
disputes concerning the election, reinstatement, and eligibility of members of the
National Council, but in all cases subject to the supervisory powers of the National
Council. Not only does our constitutional framer's goal of fully devolving this power from
the legislature fail, but the inevitable clashes of power that sometimes occur create dual
power.