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8/9/2019 Masangcay vs Comelec, 6 SCRA 27 Case Digest (Administrative Law)

Administrative Law
Arellano University School of Law
aiza ebina/2015

MASAN!A" vs !#M$L$!
% S!&A 2'
Scope of Powers of Administrative Agencies
Inherent Powers

(A!)S* On 24 October 1957, Benjamin Masangcay — then provincial treasurer o !"lan #esignate# to ta"e
charge o the receipt an# custo#y o the o$cial ballots, election orms an# supplies, as %ell as o their
#istribution, among the #i&erent municipalities o the province— %ith several others, %as charge# beore
the 'omelec %ith contempt or having opene# ( bo)es containing o$cial an# sample ballots or the
municipalities o the province o !"lan, in violation o the instructions o sai# 'ommission embo#ie# in its
resolution promulgate# on 2 *eptember 1957, an# its unnumbere# resolution #ate# 5 March 1957,
inasmuch as he opene# sai# bo)es not in the presence o the #ivision superinten#ent o schools o !"lan,
the provincial au#itor, an# the authori+e# representatives o the acionalista -arty, the .iberal -arty an#
the 'iti+ens/ -arty, as re0uire#, %hich are punishable un#er *ection 5 o the evise# lection 'o#e an#
ule 34 o the ules o 'ourt

Masangcay etal complie# %ith the summons issue# by the 'omelec to appear an# sho% cause %hy they
shoul# not be punishe# or contempt on the basis o the charge On 13 ecember 1957 the 'ommission
ren#ere# its #ecision 6n#ing Masangcay an# his corespon#ent Molo guilty as charge# an# sentencing
each o them to su&er ( months imprisonment an# pay a 6ne o -588, %ith subsi#iary imprisonment o 2
months in case o insolvency, to be serve# in the provincial jail o !"lan he other respon#ents %ere
e)onerate# or lac" o evi#ence
Masangcay brought the present petition or revie% raising as main issue the constitutionality o *ection 5
o the evise# lection 'o#e %hich grants the 'omelec as %ell as its members the po%er to punish acts o 
contempt against sai# bo#y un#er the same proce#ure an# %ith the same penalties provi#e# or in ule 34
o the ules o 'ourt in that the portion o sai# section %hich grants to the 'ommission an# members the
po%er to punish or contempt is unconstitutional or it inringes the principle un#erlying the separation o 
po%ers that e)ists among the three #epartments o our constitutional orm o government

 he *upreme 'ourt reverse# the #ecision appeale# rom insoar as Masangcay is concerne#, as %ell as the
resolution #enying his motion or reconsi#eration, insoar as it concerns him: %ithout pronouncement as to
costs

+SSU$* ;hether or not 'omelec may punish Masangcay or contempt

&UL+N*  o <n#er the la% an# the constitution, the 'omelec has not only the #uty to enorce an#
a#minister all la%s relative to the con#uct o elections, but also the po%er to try, hear an# #eci#e any
controversy that may be submitte# to it in connection %ith the elections he 'ommission, although it
cannot be classi6e# as a court o justice %ithin the meaning o the 'onstitution =*ection (8, !rticle >???@, or
it is merely an a#ministrative bo#y, may ho%ever e)ercise 0uasiju#icial unctions insoar as controversies
that by e)press provision o la% come un#er its juris#iction

 he 'omelec lac"s po%er to impose the #isciplinary penalty mete# out to Masangcay in the #ecision
subject o revie% ;hen the 'ommission e)ercises a ministerial unction it cannot e)ercise the po%er to
punish or contempt because such po%er is inherently ju#icial in nature he po%er to punish or contempt
is inherent in all courts: its e)istence is essential to the preservation o or#er in ju#icial procee#ings, an# to
the enorcement o ju#gments, or#ers an# man#ates o courts, an#, conse0uently, in the a#ministration o 
 justice

 he e)ercise o this po%er has al%ays been regar#e# as a necessary inci#ent an# attribute o courts ?ts
e)ercise by a#ministrative bo#ies has been invariably limite# to ma"ing e&ective the po%er to elicit
testimony !n# the e)ercise o that po%er by an a#ministrative bo#y in urtherance o its a#ministrative
unction has been hel# invali#

 he resolutions %hich the 'ommission trie# to enorce an# or %hose violation the charge or contempt
%as 6le# against Masangcay merely call or the e)ercise o an a#ministrative or ministerial unction or
they merely concern the proce#ure to be ollo%e# in the #istribution o ballots an# other election
paraphernalia among the #i&erent municipalities he 'ommission, thus, has e)cee#e# its juris#iction in
punishing him or contempt, an# so its #ecision is null an# voi#

&A)+#*  An administrative agency has no inherent powers, although implied powers may sometimes be
spoken of as "inherent." Thus, in the absence of any provision to punich for contempt which has always
been regarded as a necessary incident and attribute of the courts. Its exercise by administrative bodies
has been invariably limited to making eective the power to elicit testimony. And the exercise of that 
 power by an administrative body in furtherance of its administrative function has been held invalid.

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