ANG TIBAY and NATIONAL WORKERS BROTHERHOOD (NWB) v.

COURT OF
INDUSTRIAL RELATIONS (CIR) and NATIONAL LABOR UNION (NLU)
Topic: Due process in Quasi-Judicial Proceedings
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) 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.
RULING:
Yes. In the case of Goseco vs. Court of Industrial Relations et al, the Supreme
Court had occasion to point out that the although the Court of Industrial Relations may
be said to be free from the rigidity of certain procedural requirements, it 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. For administrative bodies, due process can be complied with by observing
the following:
(1) 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.

(2) 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.
(3) 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.
(4) 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.
(5)
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.
(6) 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.
(7) 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.
In this case 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 farreaching 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), hence, the NLU should be granted new trial to comply
with due process.