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Case Digest - Ang Tibay vs. Cir

The National Labor Union claimed Ang Tibay laid off its members who supported the NLU union while keeping members of the company-dominated NWB union. The Court of Industrial Relations sided with Ang Tibay and NWB. The Supreme Court then agreed to a new trial based on newly discovered evidence from NLU. On reconsideration, the Supreme Court upheld NLU's right to a new trial, finding the new evidence was previously inaccessible despite due diligence and would significantly impact the judgment. The Court outlined due process requirements for administrative bodies like substantiation of decisions and disclosure of evidence and reasoning to affected parties.

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11K views2 pages

Case Digest - Ang Tibay vs. Cir

The National Labor Union claimed Ang Tibay laid off its members who supported the NLU union while keeping members of the company-dominated NWB union. The Court of Industrial Relations sided with Ang Tibay and NWB. The Supreme Court then agreed to a new trial based on newly discovered evidence from NLU. On reconsideration, the Supreme Court upheld NLU's right to a new trial, finding the new evidence was previously inaccessible despite due diligence and would significantly impact the judgment. The Court outlined due process requirements for administrative bodies like substantiation of decisions and disclosure of evidence and reasoning to affected parties.

Uploaded by

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Copyright
© © All Rights Reserved
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CASE DIGEST

CASE NO. 8
ANG TIBAY VS. CIR - GR NO. 46496, FEBRUARY 27, 1940
G.R. NO. L-46496             FEBRUARY 27, 1940
ANG TIBAY, REPRESENTED BY TORIBIO TEODORO, MANAGER AND PROPIETOR, AND
NATIONAL WORKERS BROTHERHOOD, PETITIONERS, VS.
THE COURT OF INDUSTRIAL RELATIONS AND NATIONAL LABOR UNION, INC., RESPONDENTS.
69 Phil. 635 – Political Law – Constitutional Law – Due Process in Administrative Bodies

FACTS:

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 Workers Brotherhood
(NWB) 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.

ISSUE: 

Whether or not the National Labor Union, Inc. is entitled to a new trial.

HELD: 

Yes. The records show that the newly discovered evidence or documents obtained by NLU, which they
attached to their petition with the SC, were evidence so inaccessible to them at the time of the trial 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. Further, 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 (said newly obtained records include books of business/inventory accounts by
Ang Tibay which were not previously accessible but already existing).

The SC also outlined that administrative bodies, like the CIR, although not strictly bound by the Rules of
Court must also make sure that they comply to the requirements of due process. For administrative bodies,
due process can be complied with by observing the following:
 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.
 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.
 While the duty to deliberate does not impose the obligation to decide right, it does imply a necessity
which cannot be disregarded, namely, that of having something to support its decision. A decision
with absolutely nothing to support it is a nullity, a place when directly attached.
 Not only must there be some evidence to support a finding or conclusion but the evidence must be
“substantial.” Substantial evidence is more than a mere scintilla It means such relevant evidence as
a reasonable mind might accept as adequate to support a conclusion.
 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.
 The administrative body 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.
 The administrative body 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.

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