Angara vs Electoral Commission Case Digest

Angara vs Electoral Commission Case Digest – G.R. No. L-45081 July 15, 1936

Angara vs Electoral Commission Case Digest


FACTS

Ynsua, a candidate vying for the Angara’s position filed his election protest before the Electoral Commission. Angara sought to prohibit the Electoral Commission from taking further cognizance of the Ynsua’s motion.

Angara argues, “the constitution excludes from the COmmission’s jurisdiction the power to regulate the proceedings of such election contests. Moreover, the Commission can regulate the proceedings of election protests only if the National Assembly has not availed of its primary power to regulate such proceedings.


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Issue

Does the Electoral Commission have the power to promulgate rules notwithstanding the resolution of the National Assembly?

Ruling

Yes.

The purpose of the creation of the Electoral Commission was to transfer in its totality all the powers previously exercised by the Legislature in matters pertaining to contested elections of its members, to an independent and impartial tribunal.

The petition for a writ of prohibition against the Electoral Commission is hereby denied, with costs against the petitioner. So ordered.


We hold, therefore, that the Electoral Commission was acting within the legitimate exercise of its constitutional prerogative in assuming to take cognizance of the protest filed by the respondent Pedro Ynsua against the election of the herein petitioner Jose A. Angara, and that the resolution of the National Assembly of December 3, 1935 can not in any manner toll the time for filing protests against the elections, returns and qualifications of members of the National Assembly, nor prevent the filing of a protest within such time as the rules of the Electoral Commission might prescribe.

In view of the conclusion reached by us relative to the character of the Electoral Commission as a constitutional creation and as to the scope and extent of its authority under the facts of the present controversy, we deem it unnecessary to determine whether the Electoral Commission is an inferior tribunal, corporation, board or person within the purview of sections 226 and 516 of the Code of Civil Procedure.



Angara vs Electoral Commission Case Digest

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