Ang Tibay vs CIR, 69 Phil 635

Facts: Teodoro Toribio owns and operates Ang Tibay, a leather company which supplies the Philippine Army. Due to
alleged shortage of leather, Toribio caused the layoff of members of National Labor Union (NLU). NLU averred that
Toribios act is not valid. The CIR, decided the case and elevated it to the SC, but a motion for new trial was raised by
the NLU. But Ang Tibay filed a motion for opposing the said motion.
Issue: What is the function of CIR as a special court?
Held: To begin with the issue before us is to realize the functions of the CIR. The CIR is a special court whose
functions are specifically stated in the law of its creation which is the Commonwealth Act No. 103). It is more an
administrative board than a part of the integrated judicial system of the nation. It is not intended to be a mere
receptive organ of the government. Unlike a court of justice which is essentially passive, acting only when its
jurisdiction is invoked and deciding only cases that are presented to it by the parties litigant, the function of the CIR,
as will appear from perusal of its organic law is more active, affirmative and dynamic. It not only exercises judicial or
quasi-judicial functions in the determination of disputes between employers and employees but its functions are far
more comprehensive and extensive. It has jurisdiction over the entire Philippines, to consider, investigate, decide, and
settle any question, matter controversy or disputes arising between, and/ or affecting employers and employees or
laborers, and landlords and tenants or farm-laborers, and regulates the relations between them, subject to, and in
accordance with, the provisions of CA 103.
The CIR is free from rigidity of certain procedural requirements, but this not mean that it can in justiciable cases
coming before it, entirely ignore or disregard the fundamental and essential requirements of due process in trials and
investigations of an administrative character. There are cardinal primary rights which must be respected even
in proceedings of this character:
(1) the right to a hearing, which includes the right to present ones cause and submit evidence in support thereof;
(2) The tribunal must consider the evidence presented;
(3) The decision must have something to support itself;
(4) The evidence must be substantial;
(5) The decision must be based on the evidence presented at the hearing; or at least contained in the record and
disclosed to the parties affected;
(6) The tribunal or body or any of its judges must act on its own independent consideration of the law and facts of the
controversy, and not simply accept the views of a subordinate;
(7) The Board or body should, in all controversial questions, render its decision in such manner that the parties to the
proceeding can know the various Issue involved, and the reason for the decision rendered.
The failure to grasp the fundamental issue involved is not entirely attributable to the parties adversely affected by the
result. Accordingly, the motion for a new trial should be, and the same is hereby granted, and the entire record of this
case shall be remanded to the CIR, with instruction that it reopen the case receive all such evidence as may be
relevant, and otherwise proceed in accordance with the requirements set forth.