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ANGARA v.

ELECOM
G. R. No. L-45081 July 15, 1936
LAUREL, J.:

FACTS

On October 7, 1935, the provincial board of canvassers, proclaimed Jose


Angara as member-elect of the National Assembly for the district of Tayabas. On
December 8, 1935, Pedro Ynsua filed before the Electoral Commission a "Motion of
Protest" against the election of Angara, being the only protest filed after the
confirmation of elections, and praying, that he be declared elected member of the
National Assembly for the first district of Tayabas, or that the election of said position be
nullified. The next day, the Electoral Commission adopted a resolution providing that it
will not consider any election protest that was not submitted on or before December 9,
1935. On December 20, 1935, Angara, one of the respondents in the aforesaid protest,
filed before the Electoral Commission a "Motion to Dismiss the Protest”. On December
27, 1935, Ynsua, filed an "Answer to the Motion of Dismissal" alleging that there is no
legal or constitutional provision barring the presentation of a protest against the
election of a member of the National Assembly after confirmation. Angara, filed a
"Reply" to the aforesaid "Answer to the Motion of Dismissal" on December 31, 1935.
Finally, the case being submitted for decision, the Electoral Commission promulgated a
resolution on January 23, 1936, denying Angara’s "Motion to Dismiss the Protest."

ISSUES

1. Whether or not the Electoral Commission acted without or in excess of its


jurisdiction in taking cognizance of the protest filed against the election of
the petitioner notwithstanding the previous confirmation of such election by
resolution of the National Assembly.

RULING

1. No, the Electoral Commission was acting within the legitimate exercise of its
constitutional prerogative in assuming to take cognizance of the protest filed by
Pedro Ynsua against the election of Jose A. Angara, and that the resolution of
the National Assembly of December 3, 1935 cannot 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.
The Electoral Commission is a constitutional creation, invested with the
necessary authority in the performance and execution of the limited and
specific function assigned to it by the Constitution. 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 as if it had remained originally in the legislature.
Moreover, the creation of the Electoral Commission carried with it ex necesitate
rei the power regulative in character to limit the time with which protests
entrusted to its cognizance should be filed.
 Friends di ko masyadong sure yung issues neto, yikes!
 Kung babasahin niyo ung full case nito, I recommend na iskip niyo yung historical
background. ubos oras niyo dun.

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