Ang Tibay v.
CIR (Christian) ○ That the employer Toribio Teodoro was guilty of unfair labor
February 27, 1940 | LAUREL, J. | Due Process
PETITIONER: ANG TIBAY represented by TORIBIO TEODORO, manager
and proprietor and NATIONAL WORKERS' BROTHERHOOD
RESPONDENTS: THE COURT OF INDUSTRIAL RELATIONS and
NATIONAL LABOR UNION, INC.,
SUMMARY: The National Labor Union filed a motion for new trial and the
remanding of the case to CIR due to newly obtained evidence, against a
decision involving a labor dispute and unfair labor practices which decided in
favor of ANG TIBAY. SC allowed the motion and remanded the case back to
CIR for the evaluation of the new evidence in the interest of justice. In this case
the SC specifically identified the fundamental and essential requirements of due
process in trial and investigation of an administrative proceedings.
DOCTRINE: 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." 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
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.
FACTS:
● The case involves a labor dispute between members of the National Labor
Union and Ang Tibay for illegal termination and unfair labor practices. This
court already decided in favor of ANG TIBAY.
● Subsequently, the Solicitor-General in behalf of the respondent Court of
Industrial Relations in this case has filed a motion for reconsideration.
While National Labor Union, Inc., prays for the remanding of the case
to the Court of Industrial Relations for a new trial on a decision of the
court favoring Ang Tibay. These petitions are based on the following
findings:
○ Toribio Teodoro's claim that there was a shortage of leather soles
in ANG TIBAY making it necessary for him to temporarily lay off
the members of the National Labor Union Inc., is entirely false
○ That the supposed lack of leather materials claimed by Toribio
Teodoro was but a scheme adopted to systematically discharge all
the members of the National Labor Union, Inc., from work.
practice for discriminating against the National Labor Union, Inc.,
and unjustly favoring the National Workers' Brotherhood (Toribio
is a member)
○ That the National Workers' Brotherhood of ANG TIBAY is a
company or employer union dominated by Toribio Teodoro, the
existence and functions of which are illegal.
○ That the new evidence they are presenting are so inaccessible to
and very difficult to obtain that even with the exercise of due
diligence they could not be expected to have obtained them and
offered them as evidence in the Court of Industrial Relations and
these 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.
● Ang Tibay, has filed an opposition both to the motion for reconsideration of
the respondent Court of Industrial Relations and to the motion for new trial
of the respondent National Labor Union, Inc.
ISSUE: Whether the Motion of New Trial of National Labor Union Inc. should be
granted?
RATIO: AFFIRMATIVE.
● In the light of the fundamental principles, it is sufficient to observe that,
except as to the alleged agreement between the Ang Tibay and the National
Workers' Brotherhood, the record is barren and does not satisfy the need for
a factual basis upon which to predicate, in a rational way, a conclusion of
law.
● By and large, after considerable discussion, we have come to the conclusion
that the interest of justice would be better served if National Labor Union
Inc. is given the opportunity to present at the hearing the their new evidence
referred to in his motion and such other evidence as may be relevant to the
main issue involved.
● 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."
● 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 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 which are:
○ The right to a hearing which includes the right to present his own
case and submit evidence in support thereof.
○ The tribunal must consider the evidence presented.
○ The duty to deliberate and a necessity of having something to
 support its decision. Industrial Relations, with instruction that it reopen the case, receive all such
○ Not only must there be some evidence to support a finding or evidence as may be relevant, and otherwise proceed in accordance with the
conclusion but the evidence must be "substantial." requirements set forth hereinabove. So ordered.
■ 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.
■ Only by conning the administrative tribunal to the
evidence disclosed to the parties, can the latter be
protected in their right to know and meet the case against
them.
○ The Court of Industrial Relations 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 Court of Industrial Relations 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.

NATURE OF THE CIR

● The Court of Industrial Relations is a special court whose functions are
specifically stated in the law of its creation (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 Court of Industrial
Relations, 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 dispute arising
between, and/or affecting, employers and employees or laborers, and
landlords and tenants or farm-laborers, and regulate the relations between
them, subject to, and in accordance with, the provisions of Commonwealth
Act No. 103 (section 1).
● There is in reality here a mingling of executive and judicial functions,
which is a departure from the rigid doctrine of the separation of
governmental powers.

RULING: Accordingly, the motion for a new trial should be, and the same is
hereby granted, an the entire record of this case shall be remanded to the Court of