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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
o The number of employees involved exceeds 30
o 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 ones 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.

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