G.R. No.

L-45081 July 15, 1936

JOSE A. ANGARA, petitioner, vs. THE ELECTORAL COMMISSION, PEDRO YNSUA, MIGUEL
CASTILLO, and DIONISIO C. MAYOR, respondents.

FACTS:

The petitioner, Jose A. Angara, sought for the issuance of a writ of prohibition (an order directed
to the judge and parties of a suit in a lower court, ordering the court not to exercise jurisdiction in a
particular case) to restrain and prohibit the Electoral Commission, one of the respondents, from taking
further cognizance of the protest filed by Pedro Ynsua, another respondent, against the election of said
petitioner as member of the National Assembly for the first assembly district of the Province of Tayabas.

On October 7, 1935, the petitioner, Jose A. Angara, was proclaimed as member-elect of the
National Assembly for the said district, for having received the most number of votes. He took his oath on
November 15, 1935. On December 3, 1935, the National Assembly passed Resolution No. 8 confirming
the election of those who have not been subject of an election protest.

On December 8, 1935, however, private respondent Pedro Ynsua filed a “Motion of Protest”
against the petitioner before the Electoral Commission of the National Assembly. The following
day, December 9, 1935, the Electoral Commission adopted its own resolution of fixing December 9, 1935
as the last day of filing of protests against election, returns and qualifications of members of the National
Assembly.

On December 20, 1935, Jose A. Angara filed before the Electoral Commission a “Motion to
Dismiss the Protest” alleging that Resolution No. 8 was adopted in legitimate and that the “Motion of
Protest” filed against him was filed out of the prescribed period. The Electoral Commission denied the
“Motion to Dismiss the Protest” by Angara on January 23, 1936.

ISSUE:

1. Did the Supreme Court have a jurisdiction over the Electoral Commission and the subject matter
of the controversy upon the foregoing related facts?
2. Did the Electoral Commission act without or in excess of its jurisdiction in taking cognizance (the
power, authority, and ability of a judge to determine a particular legal matter) of the protest filed
against the election of the petitioner notwithstanding the previous confirmation of such election
by Resolution No. 8 of the National Assembly?

RULING:

1. YES. 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.
2. NO. The last provision of Article VI Section 4 of the 1935 Constitution states that the Electoral
Commission shall be the sole judge of all contests relating to the election, returns, and
qualifications of the Members of the National Assembly. The express lodging of this power in the
Electoral Commission is an implied denial of the exercise of that power by the National
Assembly. The petition for a writ of prohibition against the Electoral Commission is hereby
denied, with costs against the petitioner.