Administrative Law Case Digest Pasquin, Irish Mae

Ang Tibay vs. CIR

FACTS: A motion for reconsideration was filed by the Solicitor-General on behalf of

respondent CIR. National Labor Union on the other hand prays for the remanding of the case
to CIR for a new trial. Ang Tibay filed an opposition for both the motion for reconsideration
of CIR and the motion for a new trial by the National Labor Union (NLU). 

Toribio Teodoro owns and operates Ang Tibay, a leather company which supplies the
Philippine Army. NLU avers that employer Toribio Teodoro (of the National Workers’
Brotherhood [NWB] of Ang Tibay) made a false claim that there was a shortage of leather
soles in Ang Tibay, making it necessary for him to lay off workers. NLU alleges that such
claim was unsupported by the Bureau of Customs records and the accounts of native dealers
of leather. Such was just a scheme adopted to discharge all the members of the NLU from
work. Hence, they say that Teodoro was guilty of unfair labor practice for discriminating
against NLU and unjustly favoring NWB. 

As regards the exhibits attached to this case, NLU says that these are so inaccessible to the
respondents that even with the exercise of due diligence they could not be expected to have
obtained them and offered as evidence in the CIR. In addition, the attached documents and
exhibits are of such far-reaching importance and effect that their admission would necessarily
mean the modification and reversal of the judgment rendered herein. 

ISSUE/S: WON NLU is entitled to new trial.

HELD: Yes.

The court observed that, except as to the alleged agreement between the Ang Tibay and the
NWB, the record is barren and does not satisfy the thirst for a factual basis upon which to
predicate a conclusion of law [see Primary cardinal requirements below]. Therefore, in the
interest of justice, a new trial should commence giving the movant the opportunity to present
new evidence. 

In the case of Goseco vs. Court of Industrial Relations et al., G.R. No. 46673, promulgated
September 13, 1939, we had occasion to point out that the Court of Industrial Relations is not
narrowly constrained by technical rules of procedure, and the Act requires it to "act according
to justice 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." (Section 20, Commonwealth Act
No. 103.) It shall not be restricted to the specific relief claimed or demands made by the
parties to the industrial or agricultural dispute, but may include in the award, order or
decision any matter or determination which may be deemed necessary or expedient for the
purpose of settling the dispute or of preventing further industrial or agricultural disputes.
(section 13, ibid.) And in the light of this legislative policy, appeals to this Court have been
especially regulated by the rules recently promulgated by this Court to carry into effect the
avowed legislative purpose. The fact, however, that the Court of Industrial Relations may be
said to be free from the rigidity of certain procedural requirements does not mean that it can,
in justifiable cases before it, entirely ignore or disregard the fundamental and essential
requirements of due process in trials and investigations of an administrative character. There
are primary rights which must be respected even in proceedings of this character:
Administrative Law Case Digest Pasquin, Irish Mae

1. Right to a hearing, including the right to present one’s own case and submit evidence
in support thereof 
2. Tribunal must consider the evidence presented 
3. Decision must have something to support itself 
4. Evidence must be substantial
1. It must be relevant as a reasonable mind might accept it as adequate to support
a conclusion
2. The rules of evidence shall not be controlling so that the mere admission of
matter which would be deemed incompetent in judicial proceedings would not invalidate the
administrative order
3. Mere uncorroborated hearsay or rumor does NOT constitute substantial
evidence 
5. Decision must be rendered on the evidence presented at the hearing, or at least
contained in the record and disclosed to the parties affected
1. On boards of inquiry
1. They may be appointed for the purpose of investigating and
determining the facts in any given case
2. Their report and decision are only advisory
3. CIR may refer any industrial or agricultural dispute to a board of
inquiry, fiscal, justice of the peace, any public official but such delegation shall not affect the
exercise of the Court itself or any of its powers
6. CIR or any of its judges must act on its or his own independent consideration of the
law and facts of the controversy, and not simply accept the views of a subordinate in arriving
at the decision
7. CIR should render its decision in such a manner that the parties can know the issues
involved and the reasons for the decisions rendered.