Ang Tibay v. CIR, 69 Phil 635 (1940)

Ang Tibay v. CIR, 69 Phil 635 (1940)
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FACTS:
 

• Toribio Teodoro, owner of Ang Tibay, a leather company which supplies the Philippine Army, averred that a number of his employees were temporarily laid off due to alleged shortage of leather soles.
• On the other hand, the National Labor Union, Inc prayed for the vacation of the judgement rendered by the majority of this Court and the remanding of the case to the Court of Industrial Relations for a new trial, contended that:
  • The reason for employees lay off is entirely false and unsupported by the records of the BOC and the Books of Accounts of native dealers in leather.
  • The supposed lack of leather materials was but a sched to systematically prevent the forfeiture of the bond with the Philippine Army, despite the breach of contract
  • The National Worker’s Brotherhood registered employee’s union dominated by Teodoro is illegal for its existence and functions.
  •  Teodoro was guilty of unfair labor practice for discriminating against the NLU Inc. and unjustly favoring the National Worker’s Brotherhood
• Ang Tibay, has filed an opposition both to the motion for reconsideration of the respondent National Labor Union, Inc.
• The case then reached the CIR and eventually elevated to the SC, but a motion for new trial by the NLU contending there were inaccessible documents which could not be offered in the CIR.  That these documents, which NLU have now attached as exhibits are of such far-reaching importance and effect that their admission would necessarily mean the modification and reversal of the judgment rendered therein.

 
ISSUE:  Whether or not the National Labor Union Inc, was deprived of due process
 
RULING:
 YES. The SC concluded that the Court of Industrial Relations is a special court whose functions are specifically stated in the law of its creation (Commonwealth Act No. 103). Unlike a court of justice which is essentially passive, acting only when its jurisdiction is invoked and deciding only cases that are presented to it by the parties litigant, the function of the Court of Industrial Relations, as will appear from perusal of its organic law, is more active, affirmative and dynamic. 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 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).
The SC had occasion to point out that the 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.)
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Further the SC enumerated the requisites of administrative due process embodied as primary rights:
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.       the tribunal must consider the evidence presented
3.       The decision must have something to support itself
4.       the evidence must be "substantial"
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 CIR 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 CIR 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 Court  held that the motion for a new trial should be and the same is hereby granted, and the entire record of this case shall be remanded to the Court of Industrial Relations, with instruction that it reopen the case, receive all such evidence as may be relevant and otherwise proceed in accordance with the requirements set forth here in above.