Case Digest: Ang Tibay vs. CIR; 69 Phil 635 (1940)

 Ang Tibay v. CIR, G.R. No. L-46496,  February 27, 1940

          Due Process | Constitutional Law

Facts:

• Toribio Teodoro, the owner of Ang Tibay, claimed that some employees were temporarily laid off due to a shortage of leather soles. 
• The National Labor Union, Inc. (NLU) requested a new trial in the Court of Industrial Relation, arguing that the shortage claim was false and unsupported by evidence, and that it was a scheme to avoid contractual obligations. 
• The NLU also contended that the National Worker's Brotherhood, an employee union dominated by Teodoro, was illegal. They accused Teodoro of unfair labor practices and discrimination against the NLU.
• Ang Tibay opposed the NLU's motion for reconsideration.

Issue:
WoN the National Labor Union Inc, was deprived of due process. YES

 

Held: 

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 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."

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. 

Principle:

Cardinal primary requirements of due process in administrative proceedings:

(1) The right to a hearing which includes the right to present one's 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, and "substantial evidence" means such evidence as a reasonable mind might accept as adequate to support a conclusion;

(5) The decision must be based on the evidence presented at the hearing, or at least contained in the record and disclosed to the parties affected;

(6) The tribunal or body 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; and

(7) The board or body should, in all controversial questions, render its decisions in such manner that the parties to the proceeding can know the various issues involved, and the reason for the decision rendered.