Ang Tibay v. CIR

ANG TIBAY and NATIONAL WORKERS’ BROTHERHOOD v. COURT OF INDUSTRIAL RELATIONS and NATIONAL LABOR UNION, INC. 

27 February 1940 | Laurel 

Decision on motion for reconsideration and on motion for new trial 

Remember this case for

The cardinal primary requirements of due process in administrative proceedings

Characterization of the CIR 

Facts

An MfR 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. 

Resolution and Disposition 

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. 

MfR denied. Motion for new trial granted. Case remanded to CIR. 

Characterization of CIR 

• Special court whose functions are stated in CA No. 103 
• More of an administrative board than a part of the integrated judicial system 
• Function is more active, affirmative, dynamic 
• Exercises judicial / quasi-judicial functions in the determination of disputes between employers and employees 
• Has jurisdiction over the entire PH re: matters concerning employer-employee, landlord-tenant/farm-laborer relations 
• Can take cognizance of industrial or agricultural dispute causing or likely to cause a strike or lockout provided that
• The number of employees involved exceeds 30
• Such dispute is submitted to the Court by the Labor Sec. or by any / both of the parties to the controversy and certified by Labor Sec. as proper to be dealt with by the court
• Investigates and studies all pertinent facts related to the industry concerned when directed by the PH President 
• There is a mingling of executive and judicial functions, a departure from the rigid doctrine of the separation of governmental powers 

In Goseco v. CIR, the Court said that CA 103 requires CIR 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 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.” 

HOWEVER, this does NOT mean that CIR can entirely ignore or disregard the fundamental and essential requirements of due process in trials and investigations of an administrative character. 

Cardinal primary requirements of due process in administrative proceedings

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.