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Ang Tibay vs Court of Industrial Relations [G.R. No. L-46496.

February 27, 1940]

69 Phil. 635 Political Law Constitutional Law Due Process in


Administrative Bodies

Remedial Law Civil Procedure Motion For New Trial; Grounds

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.

HELD: Yes. 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 far-reaching
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).

The SC also outlined that administrative bodies, like the CIR, although not
strictly bound by the Rules of Court must also make sure that they comply
to the requirements of due process. 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.