G.R. No. L-45081 – 63 Phil. 139 – Political Law – Judicial Review – Electoral Commission
In the national elections of September 1935, Jose Angara won over Pedro Ynsua for the position of member of the National Assembly for the first district of the Province of Tayabas. In November 1935, Angara took his oath of office.
On December 3, 1935, the National Assembly passed Resolution No. 8 which stated that there shall be no more protests as to the election, returns, and qualifications of its members.
On December 8, 1935, Ynsua, filed before the Electoral Commission a protest against the election of Angara.
On December 9, 1935, the Electoral Commission issued a resolution which states that the last day for the filing of protests against the election, returns, and qualifications of members of the National Assembly shall be December 9, 1935.
Angara filed a Motion to Dismiss against the protest of Ynsua as he averred that the National Assembly already issued a resolution which barred the filing of protests after December 3, 1935.
Ynsua insisted that his protest must be taken cognizance by the Electoral Commission as it is the body established by the Constitution to settle disputes pertaining to the election of members of the National Assembly.
The Electoral Commission agreed with Ynsua and his protest was given due course. Angara now questions before the Supreme Court the validity of the act of the Electoral Commission in fixing the deadline of the filing of protests. Ynsua averred that the Supreme Court has no power to review the acts of the Electoral Commission.
ISSUES: (1) Whether or not the Supreme Court may review the acts of the Electoral Commission. (2) Whether or not the Electoral Commission acted without or in excess of jurisdiction in fixing the last date of filing protests despite the fact that the National Assembly fixed an earlier date.
HELD: (1) Yes. The SC emphasized that in cases of conflict between the several departments and among the agencies of the government, the judiciary, with the SC as the final arbiter, is the only constitutional mechanism devised finally to resolve the conflict and allocate constitutional boundaries.
That judicial supremacy is but the power of judicial review in actual and appropriate cases and controversies, and is the power and duty to see that no one branch or agency of the government transcends the Constitution, which is the source of all authority.
That the Electoral Commission is an independent constitutional creation with specific powers and functions to execute and perform, closer for purposes of classification to the legislative than to any of the other two departments of the government. That the Electoral Commission is the sole judge of all contests relating to the election, returns and qualifications of members of the National Assembly. But this does not mean that it is beyond the powers of the Supreme Court. Specifically, the Supreme Court has jurisdiction over the Electoral Commission and the subject matter of the present controversy for the purpose of determining the character, scope and extent of the constitutional grant to the Electoral Commission as “the sole judge of all contests relating to the election, returns and qualifications of the members of the National Assembly.”
(2) No. The grant of power to the Electoral Commission to judge all contests relating to the election, returns and qualifications of members of the National Assembly, is intended to be as complete and unimpaired. The National Assembly cannot impede or preempt such power by fixing a deadline. Otherwise, the grant of power to the Electoral Commission would be ineffective. The Electoral Commission in such case would be invested with the power to determine contested cases involving the election, returns and qualifications of the members of the National Assembly but subject at all times to the regulative power of the National Assembly. Not only would the purpose of the framers of our Constitution of totally transferring this authority from the legislative body be frustrated, but a dual authority would be created with the resultant inevitable clash of powers from time to time.
Read another version of this digest here (Separation of Powers).