Case Summary (G.R. No. 45081)
Issues Presented
- Does the Supreme Court have jurisdiction over the Electoral Commission and the present controversy?
- If so, did the Electoral Commission exceed its jurisdiction by entertaining Ynsua’s protest filed after the Assembly’s confirmation resolution?
Jurisdiction and Separation of Powers
The Court affirmed its jurisdiction under Article VIII, Section 2, of the 1935 Constitution to resolve actual controversies concerning constitutional boundaries. Although the Commission is a constitutional organ of the Legislative Department, it is not beyond judicial review when it acts outside its conferred authority.
Constitutional Grant to the Electoral Commission
Under Article VI, Section 4, of the 1935 Constitution, the Electoral Commission is “the sole judge of all contests relating to the election, returns and qualifications of the members of the National Assembly.” By vesting exclusive authority in the Commission, the Constitution withdrew from the Assembly the power to decide election contests or regulate their procedures.
Implied Power to Regulate Proceedings
The Court held that the Commission’s exclusive adjudicatory power carries, by necessary implication, the authority to prescribe procedural rules, including the time for filing protests. Absent any constitutional or statutory provision prescribing a filing period, the Commission’s December 9 rule was a valid exercise of its quasi-judicial powers.
Effect of Assembly Confirmation Resolution
Resolution No. 8 of December 3, 1935, confirming unprotested members, did not constitute a limitation on the Commission’s procedural authority. Confirmation is a legislative practice born of earlier laws and was unnecessary under the 1935 Constitution; it could not bar protests filed within the Commission’s prescribed period.
Historical and Comparative Context
The Court traced the evolution of legislative election tribunals from the U.S. and U.K. to the 1935 Philippine Constitution, emphasizing the framers’ intent to establish an impartial body free of partisan influence. The creation of the Commission remedied the abuses inherent when legislatures judged their own election contests.
Equitable and Practical Considerations
Because the Commission was not organized before December 3, 1935, an Assembly-based limitation would have barred all protests before the Commission could act. Such a result would frustrate the framers’ intent and create a procedural vacuum.
Holding
- The Supreme Court has jurisdiction to determine the scope of the Electoral Commission’s constitutional grant.
- The Commission acted within i
Case Syllabus (G.R. No. 45081)
Facts
- In the September 17, 1935 elections, Jose A. Angara, Pedro Ynsua, Miguel Castillo, and Dionisio Mayor vied for the National Assembly seat in Tayabas’s first district.
- On October 7, 1935, the provincial board of canvassers declared Angara member-elect for receiving the highest vote.
- Angara took his oath on November 15, 1935, and joined the Assembly that same month.
- December 3, 1935: The National Assembly adopted Resolution No. 8 confirming the election of members “against whom no duly presented protest” had been filed.
- December 8, 1935: Pedro Ynsua filed a protest before the Electoral Commission seeking either his own declaration as elected or nullification of Angara’s election.
- December 9, 1935: The Electoral Commission adopted rules providing that it would not consider any protest filed after that date.
- December 20, 1935: Angara moved to dismiss Ynsua’s protest, contending that Resolution No. 8 validly fixed the protest period and that the Commission lacked power to override it.
- December 27, 1935: Ynsua answered, denying any constitutional bar on post-confirmation protests.
- December 31, 1935: Angara replied to that answer.
- January 23, 1936: The Electoral Commission denied Angara’s motion to dismiss and asserted jurisdiction over Ynsua’s protest.
Procedural History
- Angara instituted an original action in the Supreme Court for a writ of prohibition against the Electoral Commission.
- He alleged the Commission acted beyond jurisdiction by entertaining Ynsua’s protest after the Assembly’s confirmation.
- Solicitor-General filed the Electoral Commission’s answer on February 25, 1936; Ynsua filed his own on March 2, 1936.
- The case was argued on March 13, 1936; a preliminary injunction request was denied on March 21.
- No appearances were made for other respondents.
Issues Presented
- Does the Supreme Court have jurisdiction over the Electoral Commission and the present controversy?
- If so, did the Commission exceed its jurisdiction by taking cognizance of Ynsua’s protest despite the Assembly’s confirmation resolution?
Constitutional and Statutory Provisions
- Const., Art. VI, Sec. 4: Establishes an Electoral Commission as “the sole judge of all contests relating to the election, returns and qualifications of the members of the National Assembly.”
- Const., Art. VIII, Secs. 1–2: Grants Supreme Court judicial power and implicit authority of review.
- Const. Ord., par. 13, Sec. 1; Tydings-McDuffie Law, Art. 7, par. 6: Referenced as potential bases for Supreme Court jurisdiction over constitutional questions.
- Jones Law (Act of Congress 1916), Sec. 18: Previously vested each legislative house with sole judgment over its contests.
- Act No. 3387, Sec. 478: Authorized each house to fix time and mann