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Ang Tibay vs. CIR (G.R. No.


Ang Tibay was a manufacturer of rubber slippers. There was a shortage of leather
soles, and it was necessary to temporarily lay off members of the National Labor
Union. According to the Union however, this was merely a scheme to systematically
terminate the employees from work, and that the shortage of soles is unsupported.
It claims that Ang Tibay is guilty of unjust labor practice because the owner,
Teodoro, is discriminating against the National Labor Union, and unjustly favoring
the National Workers Brotherhood, which was allegedly sympathetic to the employer.
The Court of Industrial Relation decided the case and elevated it to the Supreme
Court, but a motion for new trial was raised by the NLU. But the Ang Tibay filed a
motion for opposing the said motion.

The motion for new trial was raised because according to NLU, there are documents
that are so inaccessible to them that even with the exercise of due diligence they
could not be expected to have obtained them and offered as evidence in the Court of
Industrial Relations. That these documents, which NLU have now attached as exhibits
are of such far-reaching importance and effect that their admission would
necessarily mean the modification and reversal of the judgment rendered therein.

WON the union was denied due process by CIR.

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.

SC had the occasion to point out that the CIR is not narrowly constrained by
technical rules of procedure, and equity and substantial merits of the case,
without regard to technicalities or legal forms and shall not be bound by any
technical rules of legal evidence but may inform its mind in such manner as it may
deem just and equitable.

The fact, however, that the CIR may be said to be free from rigidity of certain
procedural requirements does 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

(1) the right to a hearing, which includes the right to present one's 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.

SC said there was a failure to grasp the fundamental issue involved due to failure
to receive all relevant evidence. Thus, the motion for a new trial was granted and
the entire record of this case is remanded to the CIR.