In the national elections of September 1935, Jose Angara won over

Pedro Ynsua for the position of member of the National Assembly for
the first district of the Province of Tayabas. In November 1935, Angara
took his oath of office.

On December 3, 1935, the National Assembly passed Resolution No. 8

which stated that there shall be no more protests as to the election,
returns, and qualifications of its members.

On December 8, 1935, Ynsua, filed before the Electoral Commission a

protest against the election of Angara.

On December 9, 1935, the Electoral Commission issued a resolution

which states that the last day for the filing of protests against the
election, returns, and qualifications of members of the National
Assembly shall be December 9, 1935.

Angara filed a Motion to Dismiss against the protest of Ynsua as he

averred that the National Assembly already issued a resolution which
barred the filing of protests after December 3, 1935.

Ynsua insisted that his protest must be taken cognizance by the

Electoral Commission as it is the body established by the Constitution
to settle disputes pertaining to the election of members of the National
Assembly.

The Electoral Commission agreed with Ynsua and his protest was given
due course. Angara now questions before the Supreme Court the
validity of the act of the Electoral Commission in fixing the deadline of
the filing of protests. Ynsua averred that the Supreme Court has no
power to review the acts of the Electoral Commission.

ISSUES: (1) Whether or not the Supreme Court may review the acts of
the Electoral Commission. (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.
HELD: (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 one branch or agency of the government transcends the
Constitution, which is the source of all authority.

That the Electoral Commission is an independent constitutional

creation with specific powers and functions to execute and perform,
closer for purposes of classification to the legislative than to any of the
other two departments of the government. That the Electoral
Commission is the sole judge of all contests relating to the election,
returns and qualifications of members of the National Assembly. But
this does not mean that it is beyond the powers of the Supreme Court.
Specifically, the Supreme 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.”

(2) No. The grant of power to the Electoral Commission to judge all
contests relating to the election, returns and qualifications of members
of the National Assembly, is intended to be as complete and
unimpaired. The National Assembly cannot impede or preempt such
power by fixing a deadline. Otherwise, the grant of power to the
Electoral Commission would be ineffective. The Electoral Commission in
such case would be invested with the power to determine contested
cases involving the election, returns and qualifications of the members
of the National Assembly but subject at all times to the regulative
power of the National Assembly. Not only would the purpose of the
framers of our Constitution of totally transferring this authority from
the legislative body be frustrated, but a dual authority would be created
with the resultant inevitable clash of powers from time to time.