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the BAR: Philippine Digested Cases


Friday, August 19, 2016

Constitutional Law: ANG TIBAY VS. CIR

ANG TIBAY VS. CIR

FACTS:

Petitioner, Ang Tibay has filed an opposition for both the motion for reconsideration of CIR and the
motion for a new trial by the National Labor Union.

The National Labor Union’s case: they alleged that Toribio Teodoro, who dominated the National
Workers’ Brotherhood of Ang Tibay,made a false claim that there was a shortage of leather soles in ANg
Tibay that made it necessary for him to lay off workers, however, claim was unsupported by records of
the Bureau of Customs & the accounts of native dealers of leather. Such was just a scheme adapted to
systematically discharge all the members of the NLU, inc., from work. · Unfair labor practice for
discriminating against the

National Labor Union, Inc., and unjustly favoring the National Workers' Brotherhood.· That the exhibits
hereto attached 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 Court of Industrial
Relations.

That 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.

HELD:

motion for reconsideration denied, motion for new trial granted.

Discussion of the Nature of the CIR to emphasize certain guiding principles which should be observed in
the trial of cases brought before it. Court of Industrial Relations an administrative court - exercises
judicial or quasi-judicial functions in the determination of disputes between employers and employees

- has jurisdiction over the entire Philippines, to consider, investigate, decide, and settle any question,
matter controversy or dispute arising between, and/or affecting employers and employees or laborers,
and regulate the relations between them, subject to, and in accordance with, the provisions of
Commonwealth Act No. 103 (section 1).

There is in reality here a mingling of executive and judicial functions, which is a departure from the rigid
doctrine of the separation of governmental powers.

In the case of Goseco vs. Court of Industrial

Court of Industrial Relations is not narrowly constrained by technical rules of procedure, and the Act
requires it 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." (Section 20,

Commonwealth Act No. 103.) requirements of due process in trials and investigations of an
administrative character.

1. 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. tribunal must consider the evidence presented.

3. have something to support the decision

4. evidence must be "substantial." - such relevant evidence as a reasonable mind accepts 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. Only by confining the administrative tribunal to the
evidence disclosed to the parties, can the latter be protected in their right to know and meet the case
against them.

6. The Court of Industrial Relations 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. It may be that the volume of work is such that it is literally
Relations personally to decide all controversies coming before them.

7.The Court of Industrial Relations 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.

The court observed that, except as to the alleged agreement between the Ang Tibay and the National
Worker's Brotherhood, the record is barren and does not satisfy the thirst for a factual basis upon which
to predicate, in a national way, a conclusion of law. Therefore, in the interest of justice, a new trial
should commence giving the movant the opportunity to present new evidence.

Dagitab at 1:24 AM

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