23. ANG TIBAY vs.

THE COURT OF INDUSTRIAL RELATIONS and NATIONAL LABOR

UNION, INC.,
Gr no. 46496 February 27, 1940
LAUREL, J .:
DOCTRINE: Although the CIR can act 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 evidencebut may inform its mind in such manner as it may deem just and equitable, this
does NOT mean that CIR can entirely ignore or disregard the fundamental and essential
requirements of due process in trials and investigations of an administrative character.

FACTS: Teodoro Toribio owns and operates Ang Tibay, a leather company which supplies to
the Philippine Army. Due to the alleged shortage of leather, Toribio caused the lay off of
members of National Labor Union, Inc. NLU alleges that such claim was unsupported by the
Bureau of Customs records and the accounts of native dealers of leather. Such was just a
scheme adopted to discharge all the members of the NLU from work. Hence, they say that
Teodoro was guilty of unfair labor practice for discriminating against NLU and unjustly favoring
National Workers Brotherhood.
As regards the exhibits attached to this case, NLU says that these 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. In addition, 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 herein. Hence, they pray for a
new trial to be able to present the newly obtained evidence before the CIR.

ISSUE: Whether or not there has been due process of law.

HELD: The Court ruled that there should be a new trial for NLU. All administrative bodies
cannot ignore or disregard the fundamental and essential requirements of due process. The first
of these rights is 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. Not only must
there be some evidence to support a finding or conclusion, but the evidence must be
substantial. 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 Court of Industrial Relations 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 Court of Industrial Relations 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.

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

NOTES:
Court of Industrial Relations
Special court whose functions are stated in CA No. 103
More of an administrative board than a part of the integrated judicial system
Function is more active, affirmative, dynamic
Exercises judicial / quasi-judicial functions in the determination of disputes between
employers and employees
Has jurisdiction over the entire PH re: matters concerning employer-employee, landlord-
tenant/farm-laborer relations
Can take cognizance of industrial or agricultural dispute causing or likely to cause a
strike or lockout provided that
The number of employees involved exceeds 30
Such dispute is submitted to the Court by the Labor Sec. or by any / both of the parties
to the controversy and certified by Labor Sec. as proper to be dealt with by the court
Investigates and studies all pertinent facts related to the industry concerned when
directed by the PH President
There is a mingling of executive and judicial functions, a departure from the rigid doctrine
of the separation of governmental powers