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Ang Tibay Vs CIR

The CIR ruled against the National Labor Union in a dispute with Ang Tibay shoe factory over the layoff of union members. The union claimed it was denied due process, as there were documents important to its case that were inaccessible. The Supreme Court held that while the CIR is not bound by strict procedural rules, it must still respect fundamental due process rights, including considering all relevant evidence. As there was a failure to receive all evidence, the Court granted the union's motion for a new trial and remanded the case to the CIR.

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93 views2 pages

Ang Tibay Vs CIR

The CIR ruled against the National Labor Union in a dispute with Ang Tibay shoe factory over the layoff of union members. The union claimed it was denied due process, as there were documents important to its case that were inaccessible. The Supreme Court held that while the CIR is not bound by strict procedural rules, it must still respect fundamental due process rights, including considering all relevant evidence. As there was a failure to receive all evidence, the Court granted the union's motion for a new trial and remanded the case to the CIR.

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EA
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© © All Rights Reserved
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Ang Tibay vs. CIR (G.R. No.

L-46496)
Facts: Ang Tibay was a manufacturer of rubber slippers. There was a shortage of leather soles,
and it was necessary to temporarily lay off members of the National Labor Union. According to
the Union however, this was merely a scheme to systematically terminate the employees from
work, and that the shortage of soles is unsupported. It claims that Ang Tibay is guilty of unjust
labor practice because the owner, Teodoro, is discriminating against the National Labor Union,
and unjustly favoring the National Workers Brotherhood, which was allegedly sympathetic to the
employer. The Court of Industrial Relation decided the case and elevated it to the Supreme
Court, but a motion for new trial was raised by the NLU. But the Ang Tibay filed a motion for
opposing the said motion.
The motion for new trial was raised because according to NLU, there are documents that are so
inaccessible to them 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. That these
documents, which NLU have now attached as exhibits are of such far-reaching importance and
effect that their admission would necessarily mean the modification and reversal of the judgment
rendered therein.
Issue: WON the union was denied due process by CIR.
Held: To begin with the issue before us is to realize the functions of the CIR. The CIR is a
special court whose functions are specifically stated in the law of its creation which is the
Commonwealth Act No. 103). It is more an administrative board than a part of the integrated
judicial system of the nation. It is not intended to be a mere receptive organ of the government.
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 CIR, 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 are far more comprehensive and extensive. It has jurisdiction
over the entire Philippines, to consider, investigate, decide, and settle any question, matter
controversy or disputes arising between, and/ or affecting employers and employees or laborers,
and landlords and tenants or farm-laborers, and regulates the relations between them, subject to,
and in accordance with, the provisions of CA 103.
SC had the occasion to point out that the CIR is not narrowly constrained by technical rules of
procedure, and equity and substantial merits of the case, without regard to 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 fact, however, that the CIR may be said to be free from rigidity of certain procedural
requirements does not mean that it can in justiciable cases coming before it, entirely ignore or
disregard the 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, which includes the right to present one's cause 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;
(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 own independent consideration of the
law and facts of the controversy, and not simply accept the views of a subordinate;
(7) The Board or body should, in all controversial questions, render its decision in such manner
that the parties to the proceeding can know the various Issue involved, and the reason for the
decision rendered.
SC said there was a failure to grasp the fundamental issue involved due to failure to receive all
relevant evidence. Thus, the motion for a new trial was granted and the entire record of this case
is remanded to the CIR.

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