GR 45352; (October, 1938) (CRITIQUE)
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THE AI-ASSISTED CRITIQUE
The Court correctly affirms the political question doctrine by deferring to the Electoral Commission’s exclusive constitutional authority under Article VI, Section 4, which makes it the “sole judge” of contests involving a member’s qualifications. This jurisdictional grant, previously interpreted in Angara v. Electoral Commission, is dispositive; the judiciary cannot review the merits of the Commission’s factual determination regarding respondent Bocar’s age and eligibility absent a showing of a due process violation. The petition’s attempt to secure a judicial declaration of ineligibility and to control the disbursement of emoluments through the Auditor General is a transparent effort to circumvent this constitutional allocation of power, which the Court properly rejects to maintain the separation of powers.

However, the Court’s reasoning is overly conclusory and fails to engage with the substantive constitutional issue at the heart of the protest: whether a candidate who undisputedly fails to meet the age qualification at the time of election or the commencement of the term can be a “duly elected” member. By refusing to examine whether the Commission’s decision constituted an arbitrary and capricious misinterpretation of the Constitution’s age requirement, the Court risks endorsing a precedent where a constitutional body’s decisions are insulated from any scrutiny, even on pure questions of law. The Angara precedent cited allows for review in cases of a “denial of due process,” but the Court does not analyze whether the Commission’s application of the constitutional age threshold was so irrational as to meet that standard.

Ultimately, while the dismissal is constitutionally mandated, the opinion represents a missed opportunity to clarify the limits of the Electoral Commission’s “sole judge” authority. The Court could have reinforced that while factual determinations are unreviewable, a clear constitutional violation—such as seating a member who patently lacks a mandatory qualification—might still be justiciable under the grave abuse of discretion standard to prevent a constitutional absurdity. The rigid application of non-interference here, without such nuance, potentially allows a constitutional body to disregard the Constitution’s plain terms without check, undermining the supremacy of the Constitution itself.