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IRON AND STEEL AUTHORITY, vs. CA FACTS: Iron and Steel Authority ("ISA") was created by P.

D 272 to develop and promote the iron and steel industry in the Philippines for a term of five (5) years from 9 August 1973. Its term was extended for another ten (10) years by EO 555. The National Steel Corporation ("NSC") embarked on an expansion program embracing the construction of an integrated steel mill in Iligan City. Pursuant to the expansion program of the NSC, Proclamation No. 2239 was issued by the President withdrawing from sale or settlement a large tract of public land located in Iligan City, and reserving that land for the use and immediate occupancy of NSC. Since certain portions of the said public land were occupied by a non-operational chemical fertilizer plant and related facilities owned by private respondent Maria Cristina Fertilizer Corporation ("MCFC"), Letter of Instruction (LOI), No. 1277 was issued directing the NSC to "negotiate with the owners of MCFC, for and on behalf of the Government, for the compensation of MCFC's present occupancy rights on the subject land and that should NSC and MCFC fail to reach an agreement within a (60) days from the date of LOI No. 1277, ISA was to exercise its power of eminent domain under P.D. No. 272 and to initiate expropriation proceedings in respect of occupancy rights of private respondent MCFC relating to the subject public land as well as the plant itself and related facilities and to cede the same to the NSC. Negotiations between NSC and private respondent MCFC failed. ISA placed NSC in possession and control of the land occupied by MCFC's fertilizer plant installation. MCFC contended that no valid judgment could be rendered against ISA which had ceased to be a juridical person. The trial court dismissed the case. ISA moved for reconsideration contending its juridical existence continued until the winding up of its affairs could be completed that the Republic of the Philippines should be allowed to be substituted for ISA. The trial court denied the motion for reconsideration. ISSUE: Whether or not the Republic of the Philippines is entitled to be substituted for ISA in view of the expiration of ISA's term. HELD: ISA was vested with some of the powers or attributed normally associated with juridical personality. There is, however, no provision in PD No. 272 recognizing ISA as possessing general or comprehensive juridical personality separate and distinct from that of the government. The ISA in fact appears to the Court to be a non-incorporated agency or instrumentality of the RP, or more precisely of the Government of the Philippines. ISA is a non-incorporated agency or instrumentality of the Republic, its powers, duties, functions, assets and liabilities are properly regarded as folded back into the Government of the Republic of the Philippines and hence assumed once again by theRepublic, no special statutory provision having been shown to have mandated succession thereto by some other entity or agency of the Republic. In the instant case, ISA instituted the expropriation proceedings in its capacity as an agent or delegate or representative of the Republic of the Philippines pursuant to its authority under P.D. No. 272.From the foregoing premises, it follows that the Republic of the Philippines is entitled to be substituted in the expropriation proceedings as party-plaintiff in lieu of ISA, the statutory term

of ISA having expired. Put a little differently, the expiration of ISA's statutory term did not by itself require or justify the dismissal of the eminent domain proceedings. ANG TIBAY vs. THE COURT OF INDUSTRIAL RELATIONS 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 by records. It claims that Ang Tibay is guilty of unfair labor practice because the owner, Teodoro, is discriminating against the National Labor Union, and unjustly favoring the National Workers Brotherhood, since the employer union dominated by Toribio Teodoro. 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. NLU seeks for a new trial as they were able to come up with new evidence/documents that they were not able to obtain before as they were inaccessible and they were not able to present it before in the CIR. ISSUE: Whether or not there should be a new trial in favor of NLU. HELD: Yes. All administrative bodies cannot ignore or disregard the fundamental and essential requirements of due process. The Court of Industrial Relations is more an administrative than a part of the integrated judicial system of the nation. It not only exercises judicial or quasi-judicial functions in the determination of disputes between employers and employees but its functions in the determination of disputes between employers and employees but its functions are far more comprehensive and expensive. It cannot ignore or disregard the fundamental and essential requirements of due process in trials and investigations of an administrative character which are the following: 1. 2. 3. 4. 5. 6. The right to a hearing, which includes the right to present ones case and submit evidence in support thereof. Tribunal must consider the evidence presented. Decision must have something to support it. Evidence must be substantial (more than a mere scintilla, relevant evidence a reasonable mind accepts to support a conclusion) Decision must be rendered on the evident presented at the hearing, or at least contained in the record or disclosed to the parties affected. Tribunal or body 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 a decision. The board or 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 reason for the decision rendered.


LUZON DEVELOPMENT BANK vs. ASSOCIATION OF LUZON DEVELOPMENT BANK EMPLOYEES and ATTY. ESTER S. GARCIA in her capacity as VOLUNTARY ARBITRATOR FACTS: From a submission agreement of the Luzon Development Bank (LDB) and the Association of Luzon Development Bank Employees (ALDBE) arose an arbitration case to resolve whether or not the company has violated the Collective Bargaining Agreement provision and the Memorandum of Agreement dated April 1994, on promotion. At a conference, the parties agreed on the submission of their respective Position Papers on December 1-15, 1994. Atty. Ester S. Garcia, in her capacity as Voluntary Arbitrator, received ALDBE's Position Paper on January 18, 1995. LDB, on the other hand, failed to submit its Position Paper despite a letter from the Voluntary Arbitrator reminding them to do so. As of May 23, 1995 no Position Paper had been filed by LDB. Without LDB's Position Paper, the Voluntary Arbitrator rendered a decision that the Bank has not adhered to the Collective Bargaining Agreement provision nor the Memorandum of Agreement on promotion. ISSUE: Which court has the jurisdiction for the appellate review of adjudications of all quasi-judicial entities (such as a voluntary arbitrator) HELD: Republic Act No. 6715 is silent with respect to an appeal from the decision of a voluntary arbitrator. Section 9 of B.P. Blg. 129, as amended by Republic Act No. 7902, provides that the Court of Appeals shall exercise exclusive appellate jurisdiction over all final judgments, decisions, resolutions, orders or awards of Regional Trial Courts and quasi-judicial agencies, instrumentalities, boards or commissions, including the Securities and Exchange Commission, the Employees Compensation Commission and the Civil Service Commission, except those falling within the appellate jurisdiction of the Supreme Court in accordance with the Constitution, the Labor Code of the Philippines under Presidential Decree No. 442, as amended, the provisions of this Act, and of subparagraph (1) of the third paragraph and subparagraph (4) of the fourth paragraph of Section 17 of the Judiciary Act of 1948. The voluntary arbitrator no less performs a state function pursuant to a governmental power delegated to him under the provisions therefor in the Labor Code and he falls, therefore, within the contemplation of the term "instrumentality" in the aforequoted Sec. 9 of B.P. 129. The fact that his functions and powers are provided for in the Labor Code does not place him within the exceptions to said Sec. 9 since he is a quasi-judicial instrumentality as contemplated therein. The decision or award of the voluntary arbitrator or panel of arbitrators should likewise be appealable to the Court of Appeals. This would be in furtherance of the original purpose of Circular No. 1-91 to provide a uniform procedure for the appellate review of adjudications of all quasi-judicial entities not expressly excepted from the coverage of Sec. 9 of B.P. 129 by either the Constitution or another statute.