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1.6 ANG TIBAY V.

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: Whether the Court of Industrial Relations is an administrative board.
RULING: 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.

1.7 DAZON V. YAP


610 SCRA 19
FACTS: Petitioner Dazon bought a condominium unit from Primetown where Kenneth Yap is the
president. Primetown, however failed to finish the condominium project, hence petitioner, who
had already made several downpayments, sought a refund of her payments. Primetown failed to
refund her payments. Dazon filed a criminal complaint against petitioner. Respondent filed a
Petition for Review with the Department of Justice, which after review, ordered the withdrawal of
the Information filed against him.
Petitioner thus filed a petition for review under Rule 45 on the sole question of law on
whether the Housing and Land Use Regulatory Board (HLURB) has jurisdiction to decide on the
criminal complaint she filed against the respondent and demanded for the refund of her
payments, pursuant to Section 23 of Presidential Decree (PD) No. 957 (1976), otherwise known
as "The Subdivision and Condominium Buyers' Protective Decree".
ISSUE: Whether or not, a Regional Trial court has jurisdiction over a criminal action arising from
violation of PD 957.
RULING: Not having been specifically conferred with the power to hear and decide cases,
which are criminal in nature, as well as to impose penalties therefore, we find that the Housing
and Land Use Regulatory Board (HLURB) has no jurisdiction over criminal actions arising from
violations of PD957. Jurisdiction is conferred by law and determined by the material averments
in the complaint as well as the character of the relief sought.
The primordial function of the HLURB is the regulation of the real estate trade and
business and not the conviction and punishment of criminals. It may be conceded that the
legislature may confer on administrative boards or bodies quasi-judicial powers involving the
exercise of judgment and discretion, as incident to the performance of administrative functions.
But in so doing; the legislature must state its intention in express terms that, would leave no
doubt, as even such quasi-judicial prerogatives must be limited, if they are to be valid, only to
those incidental to or in connection with the performance of administrative duties, which do not
amount to conferment of jurisdiction over a matter exclusively vested in the courts.
Administrative agencies being tribunals of limited jurisdiction can only wield such powers as are
specifically granted to them by their enabling statutes.

1.8 ESTRADA V. OMBUDSMAN


610 SCRA 19
FACTS: The Ombudsman served upon Sen. Estrada a copy of a complaint which prayed,
among others, that criminal proceedings for Plunder. Sen. Estrada filed his request to be
furnished with copies of counter-affidavits of the other respondents, affidavits of new witnesses
and other Filings (Request). However, Estradas Request to be furnished with copies of
Counter-Affidavits of the other respondents, affidavits of new witnesses and other filings was
denied
Subsequently, a Joint Resolution which found probable cause to indict Sen. Estrada and
his co-respondents with one count of plunder and 11 counts of violation of Section 3(e) of RA
No. 3019. Sen. Estrada filed a Motion for Reconsideration of the Joint Resolution and prayed for
the issuance of a new resolution dismissing the charges against him.
Without filing a Motion for Reconsideration of the Ombudsmans Order denying his
request, Sen. Estrada filed the present Petition for Certiorari under Rule 65 and sought to annul
and set aside the Order.
ISSUE: Whether the failure to furnish a copy of the counter-affidavits happened in the
administrative proceedings is tantamount to violation of due process.
RULING: The Supreme Court, in deciding this case, considered the differences in adjudicating
cases, particularly an administrative case and a criminal case:
Any lawyer worth his salt knows that quanta of proof and adjective rules vary depending
on whether the cases to which they are meant to apply are criminal, civil or administrative in
character. In criminal actions, proof beyond reasonable doubt is required for conviction; in civil
actions and proceedings, preponderance of evidence, as support for a judgment; and in
administrative cases, substantial evidence, as basis for adjudication. In criminal and civil
actions, application of the Rules of Court is called for, with more or less strictness. In
administrative proceedings, however, the technical rules of pleading and procedure, and of
evidence, are not strictly adhered to; they generally apply only suppletorily; indeed, in agrarian
disputes application of the Rules of Court is actually prohibited.
In administrative cases, where rights and obligations are finally adjudicated, what is
required is substantial evidence which cannot rest entirely or even partially on hearsay
evidence. Substantial basis is not the same as substantial evidence because substantial
evidence excludes hearsay evidence while substantial basis can include hearsay evidence.

1.9 IN RE ALLEGATIONS MADE UNDER OATH AT THE SENATE RIBBON COMMITTEE


AGAINST ASSOCIATE JUDGE GREGORY S. ONG, SANDIGANBAYAN
FACTS: In the middle of 2013, the local media ran an expose involving billions of government
funds channeled through bogus foundations dubbed as the "pork barrel scam. In the course of
the investigation conducted by the Senate Blue Ribbon Committee, the names of certain
government officials and other individuals were mentioned, among whom is incumbent
Sandiganbayan Associate Justice Gregory S. Ong, herein respondent.
Rappler published an article entitled "Exclusive: Napoles Parties with Anti-Graft Court
Justice" showing a photograph of Mrs. Napoles together with the respondent. The respondent
denied knowing Mrs. Napoles.
In a letter addressed to Chief Justice Sereno, respondent meticulously explained the
controversial photograph which raised questions on his integrity as a magistrate, particularly in
connection with the decision rendered by the Sandiganbayan' s Fourth Division in the Kevlar
helmet cases, which convicted some of the accused but acquitted Mrs. Napoles.
Chief Justice Sereno then requested the Court En Banc to conduct an investigation motu
proprio under this Court's power of administrative supervision over members of the judiciary and
members of the legal profession.
The investigating officer recommended that respondent Justice Gregory S. Ong be
found guilty of gross misconduct, dishonesty, and impropriety, all in violations of the New Code
of Judicial Conduct for the Philippine Judiciary and be meted the penalty of dismissal based on
the testimonies of Luy, Sula and Rufo (witnesses).
ISSUE: Whether the respondent should be dismissed based on substantial evidence.
RULING: We cannot overemphasize that in administrative proceedings, only substantial
evidence, i.e., that amount of relevant evidence that a reasonable mind might accept as
adequate to support a conclusion, is required. The standard of substantial evidence is satisfied
when there is reasonable ground to believe that respondent is responsible for the misconduct
complained of, even if such evidence might not be overwhelming or even preponderant.

1.10 OCA V. PASCUAL


610 SCRA 19
FACTS: A certain Ceferino Tigas wrote a letter, addressed to Hon. Reynaldo Suarez of the
Office of the Court Administrator of the Supreme Court, charging that irregularities and
corruption were being committed by the respondent Presiding Judge.
Edward Villarta, Cruz declared that he was the accused in a Criminal Case charged with
the crime of Frustrated Murder. Respondent judge, after conducting the preliminary investigation
of the case, decided that the crime he committed was only physical injuries and so, respondent
judge assumed jurisdiction over the case. Cruz believed that he was made to understand by the
respondent that, in view of his favorable action, Cruz was to give to respondent a sum of money.
Respondent judge is believed to be a drunkard and, in all probability, would need money to
serve his vice.
ISSUE: Whether the evidences presented against Judge Filomeno Pascual were strong enough
to convict him.
RULING: The ground for the removal of a judicial officer should be established beyond
reasonable doubt. Such is the rule where the charges on which the removal is sought is
misconduct in office, willful neglect, corruption, incompetency, etc. The general rules in regard to
admissibility of evidence in criminal trials apply.
Reasonable doubt is the inability to let the judicial mind rest easy upon the certainty of
guilt after a thorough investigation of the whole evidence. The principle of reasonable doubt
being applicable in the instant case, therefore, we find that the alleged act of bribery committed
by respondent has not been sufficiently and convincingly proven to warrant the imposition of any
penalty against respondent.