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Ang Tibay V CIR (Digest)

The CIR granted a new trial in the labor dispute between Ang Tibay shoe company and the National Labor Union. [1] A new trial was warranted because the CIR's initial decision lacked substantial evidence and failed to satisfy requirements of due process. [2] Specifically, the record did not contain enough facts to rationally conclude whether Ang Tibay had committed unfair labor practices. [3] A new hearing would allow both parties to present relevant evidence and for the CIR to properly consider the issues and provide reasons for its decision.

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0% found this document useful (0 votes)
259 views4 pages

Ang Tibay V CIR (Digest)

The CIR granted a new trial in the labor dispute between Ang Tibay shoe company and the National Labor Union. [1] A new trial was warranted because the CIR's initial decision lacked substantial evidence and failed to satisfy requirements of due process. [2] Specifically, the record did not contain enough facts to rationally conclude whether Ang Tibay had committed unfair labor practices. [3] A new hearing would allow both parties to present relevant evidence and for the CIR to properly consider the issues and provide reasons for its decision.

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Luis Lopez
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Ang Tibay v.

CIR
69 Phil. 365 (1940)
J. LAUREL
FACTS OF THE CASE:
 The Solicitor-General, in behalf of CIR, has filed for a motion for reconsideration
 Other respondent National Labor Union, Inc., on the other hand, prays for the vacation of
the judgment and the remanding of the case to the CIR for a new trial, and avers the
following:
o Toribio Teodoro's claim that on September 26, 1938, there was shortage of
leather soles in ANG TIBAY making it necessary for him to temporarily lay off
the members of the National Labor Union Inc., is entirely false and
unsupported by the records of the Bureau of Customs and the Books of Accounts
of native dealers in leather.
o The supposed lack of leather materials claimed by Toribio Teodoro was but a
scheme adopted to systematically discharge all the members of the National
Labor Union, Inc., from work.
o Toribio Teodoro's letter to the Philippine Army dated September 29, 1938, (re
supposed delay of leather soles from the States) was but a scheme to
systematically prevent the forfeiture of this bond despite the breach of his
CONTRACT with the Philippine Army.
o The National Workers' Brotherhood of ANG TIBAY is a company or employer
union dominated by Toribio Teodoro, the existence and functions of which are
illegal.
o In the exercise by the laborers of their rights to collective bargaining, majority
rule and elective representation are highly essential and indispensable.
o The century provisions of the Civil Code which had been the principle source of
dissensions and continuous civil war in Spain cannot and should not be made
applicable in interpreting and applying the salutary provisions of a modern
labor legislation of American origin where industrial peace has always been the
rule
o Toribio Teodoro was guilty of unfair labor practice for discriminating against
the National Labor Union, Inc., and unjustly favoring the National Workers’
Brotherhood
o The exhibits in the case 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
o 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 herein
 Petitioner filed an opposition to both aforementioned motions

HELD
 It is not necessary to pass upon the motion for reconsideration of the Solicitor General
 The Court of Industrial Relations is a special court that plays a more affirmative, active,
and dynamic role
o It not only exercises judicial or quasi-judicial functions in the determination of
disputes between employers and employees, but its functions are far more
comprehensive and extensive
o It has jurisdiction over the entire Philippines, toconsider, investigate, decide, and
settle any question, matter controversy or dispute arising between, and/or
affecting, employers and employees or laborers, and landlords and tenants or
farm-laborers, and regulate the relations between them, subject to, and in
accordance with the law creating it—CA No.103
o As such, it has been held before that they are not narrowly constrained by
technical rules of procedure and of legal evidence but may inform its mind in
such manner as it may deem just and equitable
 It shall not be restricted to the specific relief claimed or demands made by
the parties to the industrial or agricultural dispute, but may include in the
award, order or decision any matter or determination which may be
deemed necessary or expedient in settling a dispute or preventing future
disputes
o However, this does not mean that said court can entirely ignore fundamental and
essential requirements of due process in trials and investigations of an
administrative character.
 There are cardinal primary rights which must be respected even in
proceedings of this character:
(1) The right to a hearing – 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) A decision must have basis to support it; without such, it is a nullity.
This emanates from a more fundamental principle that the genius of
constitutional government is contrary to the vesting of unlimited power
anywhere. Law is both a grant and a limitation upon power.

(4) The evidence required is substantial. It means such relevant evidence


as a reasonable mind might accept as adequate to support a conclusion.

Mere uncorroborated hearsay or rumor does not constitute substantial


evidence.

(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 parties be protected in their right to know and meet
the case against them.

Boards of inquiry may be appointed for the purpose of investigating and


determining the facts in any given case, but their report and decision are
only advisory.
(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 decisions rendered.
The performance of this duty is inseparable from the authority conferred
upon it.
 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, 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.
o This result, however, does not now preclude the concession of a new trial
prayed for by the respondent National Labor Union, Inc.
o Justice would be better served if the petitioner 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.
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.

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