Case Digest (G.R. No. 45081)
Facts:
Jose A. Angara v. The Electoral Commission, Pedro Ynsua, Miguel Castillo, and Dionisio C. Mayor, G.R. No. 45081, July 15, 1936, the Supreme Court En Banc, Laurel, J., writing for the Court.
Petitioner Jose A. Angara was proclaimed member-elect of the National Assembly for the First District of Tayabas after the September 17, 1935 elections, was proclaimed by the provincial board of canvassers on October 7, 1935, and took his oath on November 15, 1935. On December 3, 1935 the National Assembly adopted Resolution No. 8 “confirming the acts” of those deputies against whom no protest had been presented.
Respondent Pedro Ynsua (one of Angara’s electoral opponents) filed a motion of protest against Angara’s election shortly after December 3; the record reflects that the Electoral Commission met and on December 9, 1935 adopted rules including paragraph 6 fixing that date as the last day for the presentation of protests. Angara moved the Electoral Commission on December 20, 1935 to dismiss Ynsua’s protest on the ground that Resolution No. 8 of the National Assembly had the effect of cutting off protests filed after December 3; Ynsua answered December 27 and Angara replied December 31. On January 23, 1936 the Electoral Commission denied Angara’s motion to dismiss and declared itself with jurisdiction to entertain the protest.
Angara then instituted an original action in this Court praying for a writ of prohibition to restrain the Electoral Commission from proceeding with Ynsua’s protest. The Solicitor-General answered for the Electoral Commission, contending the Commission, a constitutional instrumentality with quasi‑judicial powers, had implied authority to adopt rules and that its acts were beyond the reach of a writ of prohibition; Ynsua also answered claiming the protest had been timely filed and that t...(Subscriber-Only)
Issues:
- Does the Supreme Court have jurisdiction to entertain an original action (writ of prohibition) directed at the Electoral Commission and the subject matter presented by the admitted facts?
- Did the Electoral Commission act without or in excess of its jurisdiction in assuming cognizance of the protest against Angara’s election notwithstanding the National Assembly’s December ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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