University of the Philippines College of Law

JTR

Topic The Due Process Clause - Procedure

Case No. 69 Phil. 635
Case Name Ang Tibay and National Workers’ Brotherhood v. Court of Industrial Relations and National Labor Union (NLU)
Ponente Laurel

SUMMARY (from Uber Digests)

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 Worker’s
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.

RELEVANT FACTS
 This is a labor dispute involving Ang Tibay (a leather company), and the National Labor Union. Basically, the respondents want
to remand the case back to the CIR (they lost na in the SC). Respondents claim that (among other things):
o The claim of Teodoro that there is a leather and leather sole shortage to cause the temporary lay-offs of NLU members
is totally false, and that it is but a scheme adopted to systematically lay-off NLU members from work
o That the National Workers' Brotherhood of ANG TIBAY is a company or employer union dominated by Teodoro, the
existence and functions of which are illegal. The petitioner, 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.
 The decision deemed it necessary to discuss the nature of the CIR and how cases under it are heard before it disposed of the
motion for new trial of the respondent NLU

ISSUES
 Whether or not a new trial should be granted the NLU?

RATIO DECIDENDI

Issue Ratio
Whether “We have re-examined the entire record of the proceedings had before the Court of Industrial Relations in this case,
or not a and we have found no substantial evidence to indicate that the exclusion of the 89 laborers here was due to their union
new trial affiliation or activity. The whole transcript taken contains what transpired during the hearing and is more of a record of
should be contradictory and conflicting statements of opposing counsel, with sporadic conclusion drawn to suit their own views. It
granted is evident that these statements and expressions of views of counsel have no evidentiary value.”  basically walang
the NLU? kuwenta yung existing piece of evidence

YES A word about the functions of the CIR:

 It is more an administrative board than part of the integrated judicial system of the nation. Its role is more active
and dynamic, versus a court of justice which is passive (only when its JD is invoked and when cases are
presented to it)
 The CIR has the power to consider, investigate, decide, and settle any question, matter, controversy, or dispute
arising between employers and employees, landlords and tenants, etc. (as granted by CA 103)  the conflict
may relate to wages, hours of labor, conditions of employment, etc.
 It may employ arbitration, mediation or conciliation, or to order official investigation and compulsory arbitration
in order to determine specific controversies
 BASTA: there is in reality a mingling of executive and judicial functions, which is a departure from the
rigid doctrine of the separation of governmental powers

The CIR is not narrowly constrained by technicalities and procedure (i.e. it shall act according to justice and equity, and
it shall not be restricted to the specific relief claimed or demands made by the parties)  BUT this does not mean it
 University of the Philippines College of Law
JTR

is totally free from fundamental and essential requirements of due process in trials and investigations of an
administrative character. THESE ARE THE CARDINAL PRIMARY RIGHTS WHICH MUST BE RESPECTED EVEN
IN PROCEEDINGS OF THIS CHARACTER (7)  THE STAR OF THE SHOW
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. The decision of the tribunal should be supported by something. A decision with absolutely nothing to support
it is a nullty, a place when directly attached
4. The evidence supporting the finding or conclusion must be substantial (such relevant evidence as a reasonable
mind might accept as adequate to support a conclusion)
a. This does not include uncorroborated hearsay or rumors
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.
a. But still, it still needs to comply with the authorized legal methods of securing evidence and informing
itself of facts material and relevant to the controversy
b. Even though the CIR can delegate its power to a local board, fiscal, justice, etc., such delegation shall
not affect the exercise of the court itself of any of its powers
6. The 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 a decision
a. In the US, subordinates can render final decisions, but in the Philippines, there is no such statutory
authority
7. The CIR should 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.

In the light of the foregoing fundamental principles, it is sufficient to observe here that, except as to the alleged
agreement between the Ang Tibay and the National Workers' Brotherhood (appendix A), the record is barren and does
not satisfy the thirst for a factual basis upon which to predicate, in a rational way, a conclusion of law.

BUT
“By and large, after considerable discussion, we have come to the conclusion that the interest of justice would be better
served if the movant is given opportunity to present at the hearing the documents referred to in his motion and such
other evidence as may be relevant to the main issue involved.”
o Petitioner further alleges under oath that the exhibits attached to the petition to prove his substantial averments
"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"  sinasabi lang na to
acquire the evidence they desire would be impossible for the respondents
o and that the documents attached to the petition "are of such far reaching importance and effect that their
admission would necessarily mean the modification and reversal of the judgment rendered therein."  sinasabi
lang na enough na yung appendix A attached here to dismiss the MFR for a new trial

FINAL WORD: The legislation which created the Court of Industrial Relations and under which it acts is new. The failure
to grasp the fundamental issue involved is not entirely attributable to the parties adversely affected by the result

RULING

Accordingly, 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 hereinabove. So ordered.

Motion for new trial granted and cause remanded with instructions.