ANG TIBAY Petitioners, vs. The Court of Industrial Relations Respondents
ANG TIBAY Petitioners, vs. The Court of Industrial Relations Respondents
ANG TIBAY Petitioners, vs. The Court of Industrial Relations Respondents
vs.
THE COURT OF INDUSTRIAL RELATIONS respondents.
G.R. No. L-46496 February 27, 1940
Facts:
• Teodoro Toribio owns and operates Ang Tibay, a leather company which
supplies the Philippine Army.
• The case reached the Court of Industrial Relations (CIR) where Toribio and
NWB won.
• Eventually, NLU went to the Supreme Court prays for the vacation of
the judgement rendered by the majority of this Court and the
remanding of the case to the Court of Industrial Relations for a new
trial, on the ground that the supposed lack of leather materials claimed
by Toribio Teodoro was but a scheme to systematically prevent the
forfeiture of this bond despite the breach of his contract with the
Philippine Army.
• That the employer Toribio Teodoro was guilty of unfair labor practice
for discriminating against the National Labor Union, Inc. and unjustly
favoring the National Workers’ Brotherhood.
Issue:
Whether or not the issues should be properly directed, resolved or determined by the
Court of Industrial Relation.
Held:
• Yes, The CIR is a special court whose functions are specifically stated in the law of its
creation. It is more of an administrative than part of the integrated judicial system of
the nation. It is not intended to be a more receptive organ of the Government.
• The CIR 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 CIR 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 decision rendered. The performance of this duty is inseparable from
the authority conferred upon it.
• Accordingly, the motion for new trial should be and the same is hereby granted, and
the entire record of this case shall be remanded to the CIR with instruction that it
reopen the case, receive all such evidence as may be relevant and otherwise proceed
in accordance w/ the requirements set forth herein above.
Cardinal primary rights of due process in administrative proceedings
• Right to a hearing, including the right to present one’s own case and
submit evidence in support thereof
• Tribunal must consider the evidence presented
• Decision must have something to support itself
• Evidence must be substantial
• It must be relevant as a reasonable mind might accept it as adequate
to support a conclusion
• 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
• Mere uncorroborated hearsay or rumor does NOT constitute
substantial evidence
Cardinal primary requirements of due process in administrative
proceedings
• 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
• CIR should render its decision in such a manner that the parties can
know the issues involved and the reasons for the decisions rendered.