Ang Tibay vs. CIR - GR No.

46496, February 27, 1940

G.R. NO. L-46496             FEBRUARY 27, 1940
ANG TIBAY, REPRESENTED BY TORIBIO TEODORO, MANAGER AND
PROPIETOR, AND 
NATIONAL WORKERS BROTHERHOOD, PETITIONERS, VS. 
 THE COURT OF INDUSTRIAL RELATIONS AND NATIONAL LABOR UNION,
INC., RESPONDENTS.
69 Phil. 635 – Political Law – Constitutional Law – Due Process in Administrative Bodies

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 lay off of a number of
his employees. However, the National Labor Union, Inc. (NLU) questioned the validity of said
lay off as it averred that the said employees laid off were members of NLU while  no
members of the rival labor union National Workers Brotherhood (NWB) were laid off. NLU
claims that NWB is a company dominated union and Toribio was merely busting NLU.

The case reached the Court of Industrial Relations (CIR) where Toribio and NWB won.
Eventually, NLU went to the Supreme Court invoking its right for a new trial on the ground of
newly discovered evidence. The Supreme Court agreed with NLU. The Solicitor General,
arguing for the CIR, filed a motion for reconsideration.

ISSUE: 

Whether or not the National Labor Union, Inc. is entitled to a new trial.

HELD: 

Yes. The records show that the newly discovered evidence or documents obtained by NLU,
which they attached to their petition with the SC, were evidence so inaccessible to them at
the time of the trial 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. Further, 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
(said newly obtained records include books of business/inventory accounts by Ang Tibay
which were not previously accessible but already existing).

The SC also outlined that administrative bodies, like the CIR, although not strictly bound by
the Rules of Court must also make sure that they comply to the requirements of due
process. For administrative bodies, due process can be complied with by observing the
following:
 The right to a hearing which includes the right of the party interested or affected to
present his own case and submit evidence in support thereof.
 Not only must the party be given an opportunity to present his case and to adduce
evidence tending to establish the rights which he asserts but the tribunal must consider the
evidence presented.
 While the duty to deliberate does not impose the obligation to decide right, it does
imply a necessity which cannot be disregarded, namely, that of having something to support
its decision. A decision with absolutely nothing to support it is a nullity, a place when directly
attached.
 Not only must there be some evidence to support a finding or conclusion but the
evidence must be “substantial.” Substantial evidence is more than a mere scintilla It means
such relevant evidence as a reasonable mind might accept as adequate to support a
conclusion.
 The decision must be rendered on the evidence presented at the hearing, or at least
contained in the record and disclosed to the parties affected.
 The administrative body or any of its judges, therefore, 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 a decision.
 The administrative body should, in all controversial questions, render its decision in
such a manner that the parties to the proceeding can know the various issues involved, and
the reasons for the decisions rendered. The performance of this duty is inseparable from the
authority conferred upon it.

Ang Tibay vs. CIR (G.R. No. L-46496)

Facts:
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.

Issue:
WON the union was denied due process by CIR.

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.
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 character:

(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.