Case Digest (G.R. No. L-63277) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose A. Angara v. The Electoral Commission, et al. (63 Phil. 139, July 15, 1936), petitioner Jose A. Angara was proclaimed member‐elect of the National Assembly for Tayabas’s First District following the September 17, 1935 elections and took his oath on November 15, 1935. On December 3, 1935, the Assembly adopted Resolution No. 8 confirming the election of all members against whom no protest had been filed. Five days later, respondent Pedro Ynsua filed a protest with the Electoral Commission—constituted under the 1935 Constitution as the “sole judge of all contests relating to the election, returns, and qualifications of the members of the National Assembly”—seeking to annul Angara’s election or be declared the real winner. On December 9, 1935, the Commission herself adopted rules fixing that day as the last for filing protests. Angara moved to dismiss Ynsua’s protest as filed out of time under the Assembly’s confirmation resolution; Ynsua answered that no constitutional prov Case Digest (G.R. No. L-63277) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Election and Proclamation
- September 17, 1935 – National Assembly election in Tayabas 1st district: Angara, Ynsua, Castillo, Mayor candidates.
- October 7, 1935 – Provincial board of canvassers proclaims Jose A. Angara member-elect.
- November 15, 1935 – Angara takes his oath of office.
- December 3, 1935 – National Assembly adopts Resolution No. 8 confirming all election returns against which no protest has been filed.
- December 8, 1935 – Pedro Ynsua files protest with the Electoral Commission, seeking to nullify Angara’s election or to be declared elected.
- Electoral Commission Proceedings and Motions
- December 9, 1935 – Electoral Commission adopts rule (paragraph 6) barring any protest not filed on or before that date.
- December 20, 1935 – Angara files Motion to Dismiss, arguing Assembly’s Resolution No. 8 set the protest period and Commission lacks power to hear late protests.
- December 27, 1935 – Ynsua files Answer, contending no law bars post-confirmation protests and Commission has jurisdiction.
- December 31, 1935 – Angara files Reply.
- January 23, 1936 – Commission denies Motion to Dismiss, assumes jurisdiction over Ynsua’s protest.
- February 25 and March 2, 1936 – Solicitor-General and Ynsua file answers defending Commission’s authority.
- March 21, 1936 – Supreme Court denies preliminary injunction petition.
Issues:
- Supreme Court Jurisdiction
- Does the Supreme Court have jurisdiction over the Electoral Commission and this controversy?
- Commission’s Jurisdictional Limits
- Did the Electoral Commission act without or in excess of its jurisdiction by entertaining Ynsua’s protest after the Assembly’s December 3 confirmation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)