ANG TIBAY v.

THE COURT OF INDUSTRIAL RELATIONS

G.R. No. 46496
February 27, 1940
Laurel, J.

SUBJECT MATTER:
II. Legislative Department; A. Nature of Legislative Power; Law-Making Distinguished From Law-Execution; b)
Ascertainment of Facts

Petitioner(s): ANG TIBAY, represented by TORIBIO TEODORO, manager and proprietor, and NATIONAL
WORKERS’ BROTHERHOOD

Respondent(s): THE COURT OF INDUSTRIAL RELATIONS and NATIONAL LABOR UNION, INC.

SUMMARY:
In 1938, 89 employees of Ang Tibay, a manufacturer of leather goods, were laid off. All 89 employees were members of
the National Labor Union. The company’s proprietor, Toribio Teodoro, claimed that the layoffs were due to the shortage of
leather soles that year. The National Labor Union contended that the employees were dismissed because of their
membership in the union. It accused Teodoro of unfair labor practice for discriminating against the National Labor Union
and unjustly favoring the National Workers’ Brotherhood. Prior to the institution of the present case, the Supreme Court
had ruled in favor of Ang Tibay and dismissed the National Labor Union’s allegation of unfair labor practice. The National
Labor Union now prays that the judgment of the Supreme Court be vacated and the case be remanded to the Court of
Industrial Relations for a new trial.

ISSUE: The issue here was whether or not the motion for new trial filed by the National Labor Union should be granted in
order to allow it to present evidence disproving Ang Tibay’s claim that there was a shortage in leather shoes that
warranted the dismissal of 89 employees, all members of the union.

The Supreme Court held that the motion for new trial should be granted and the case should be remanded to the Court of
Industrial Relations for reception of evidence.
o It gave the National Labor Union the opportunity to prove that the allegation of leather shortage was a mere
scheme adopted by Ang Tibay to discharge members of the union.
o The National Labor Union had argued that the claim of leather shortage was false and unsupported by the records
of the Bureau of Customs and the Books of Accounts of native dealers in leather.
o It wanted to offer in evidence these two sets of documents: the records of the Bureau of Customs and the
Books of Accounts of native dealers in leather.

EXHIBITS INACCESSIBLE AND OF FAR REACHING IMPORTANCE

o The union alleged under oath that the exhibits were “so inaccessible [. . .] that even with the exercise of due
diligence [it] could not have obtained them and offered them [in] evidence [before] the Court of Industrial
Relations.”
o Furthermore, the union contended that the pieces of evidence were “of such far reaching importance and effect
that their admission would necessarily mean the modification and reversal of the judgment.”

CONCLUSION: In view of these arguments, the Court concluded that the interest of justice would be better served if the
National Labor Union were given the opportunity to present the documents at a hearing before the Court of Industrial
Relations.

The Supreme Court also enumerated the cardinal primary rights that ought to be respected even in administrative
proceedings in line with the fundamental requirements of due process:

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 1) the first right is the right to a hearing: every party must be given the opportunity to present his case and to
submit evidence in support thereof;
2) the tribunal must consider the evidence presented by the party;
3) the tribunal’s decision must have factual support;
4) the evidence must be substantial;
5) The decision must be rendered on the evidence presented, or at least contained in the record and disclosed to
the parties affected;
6) The tribunal or any of its judges must act on its or his own independent consideration of the law and facts of the
controversy, and it may not simply accept the views of a subordinate in arriving at a decision; and lastly,
7) the tribunal must render its decision in such a manner that the parties can know the various issues involved
and the reasons for the decision rendered.

ANTECEDENT FACTS:
● Toribio Teodoro was the proprietor of Ang Tibay, a manufacturer of leather goods.
● In 1938, 89 employees of Ang Tibay, all members of the National Labor Union, were dismissed. Teodoro claimed
that the layoffs were due to the shortage of leather soles that year. The National Labor Union claimed that the
employees were dismissed because of their membership in the union, and that Teodoro was guilty of unfair labor
practice for discriminating against the National Labor Union and unjustly favoring the National Workers’
Brotherhood.
● Prior to the institution of the present case, the Supreme Court had ruled in favor of Ang Tibay and Teodoro and
dismissed the National Labor Union’s allegation of unfair labor practice.
● The National Labor Union now prays that the judgment of the Supreme Court be vacated and the case be
remanded to the Court of Industrial Relations for the conduct of a new trial.
○ It argues that Teodoro’s claim of leather shortage is false and unsupported by the records of the Bureau
of Customs and the Books of Accounts of native dealers in leather.
○ The National Labor Union attached documents and exhibits that it said were “of such far-reaching
importance and effect that their admission would necessarily mean the modification and reversal of the
judgment.”
○ The Court of Industrial Relations filed a motion for reconsideration, not a motion for new trial.
○ Ang Tibay opposed both the Court of Industrial Relation’s motion for reconsideration and the National
Labor Union’s motion for new trial.

ISSUE(S), RULE, AND ANALYSIS:

ISSUE(S):
1. WON the motion for new trial filed by the National Labor Union should be granted in order to allow it to present
evidence disproving Ang Tibay’s claim that there was a shortage in leather shoes that warranted the dismissal of
89 employees — YES

RULE (APPLICABLE LAW/JURISPRUDENCE):

1. Commonwealth Act No. 103 (the law creating the Court of Industrial Relations)
o § 1. There is hereby created a Court of Industrial Relations, which shall have 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 landlords and tenants or
farm-laborers, and regulate the relations between them, subject to, and in accordance with, the provisions
of this Act. [. . .]

o § 4.  Strikes and lockouts. — The Court shall take cognizance for purposes of prevention, arbitration,
decision and settlement, of any industrial or agricultural dispute causing or likely to cause a strike or
lockout, arising from differences as regards wages, shares or compensation, hours of labor or conditions
of tenancy or employment, between employers and employees or laborers and between landlords and
tenants or farm-laborers, provided that the number of employees, laborers or tenants or farm-laborers
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 involved exceeds thirty, and such industrial or agricultural dispute is submitted to the Court by the
Secretary of Labor, or by any or both of the parties to the controversy and certified by the Secretary of
Labor as existing and proper to be dealt with by the Court for the sake of public interest. In all such cases,
the Secretary of Labor or the party or parties submitting the disputes, shall clearly and specifically state in
writing the questions to be decided. Upon the submission of such a controversy or question by the
Secretary of Labor, his intervention therein as authorized by law, shall cease.

The Court shall, before hearing the dispute and in the course of such hearing, endeavor to reconcile the
parties and induce them to settle the dispute by amicable agreement. If any agreement as to the whole or
any part of the dispute is arrived at by the parties, a memorandum of its terms shall be made in writing,
signed and acknowledged by the parties thereto before the Judge of the Court or any official acting in his
behalf and authorized to administer oaths or acknowledgments, or, before a notary public. The
memorandum shall be filed in the office of the Clerk of the Court, and, unless otherwise ordered by the
Court, shall, as between the parties to the agreement, have the same effect, and be deemed to be, a
decision or award.
2. Const. art. III, § 1
 No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied
the equal protection of the laws.

ANALYSIS:

RULING APPLICATION OF RULE BASED ON FACTS

1. YES, the motion for new trial ● The Court found that the record was barren and there was no factual
should be granted and the basis on which to predicate a conclusion of law. It granted the motion
case should be remanded to for new trial so that the National Labor Union could prove that
the Court of Industrial Toribio’s allegation of leather shortage was just a scheme adopted by
Relations for reception of Ang Tibay to discharge all members of the National Labor Union.
evidence. ● To prove its claim, the National Labor Union wanted to offer in
evidence records of the Bureau of Customs and Books of Accounts of
native dealers in leather. The Union further alleged under oath that
the exhibits were “so inaccessible [. . .] that even with the exercise of
due diligence they could not have obtained them and offered them [in]
evidence [before] the Court of Industrial Relations.”
o Furthermore, the pieces of evidence were “of such
far reaching importance and effect that their
admission would necessarily mean the modification
and reversal of the judgment.”
● In view of these arguments, the Court concluded that the interest of
justice would be better served if the National Labor Union were given
the opportunity to present the documents at a hearing.

Due Process Requirements in Administrative Cases

● The Court of Industrial Relations is not narrowly constrained by
technical rules of procedure, and the law requires it to “act according
to justice and equity and [the] substantial merits of the case without
regard to technicalities or legal forms[.]” It 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.”
o It shall not be restricted to the specific relief claimed
or demands made by the parties to the industrial or
agricultural dispute. It may include in the award,

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 order, or decision any matter or determination which
may be deemed necessary or expedient for the
purpose of settling the dispute or of preventing
further industrial or agricultural disputes.
● However, although the Court of Industrial Relations is not bound by
the rigidity of certain procedural requirements, there are cardinal
primary rights that it ought to respect in line with the fundamental and
essential requirements of due process.
1. The right to a hearing: The party interested or affected has a
right to present his own case and submit evidence in support
thereof.
2. The tribunal must consider the evidence presented by the
party.
o “The right to adduce evidence, without the
corresponding duty on the part of the board to
consider it, is vain. Such right is conspicuously futile
if the person or persons to whom the evidence is
presented can thrust it aside without notice or
consideration.”
3. The tribunal’s decision must have factual and evidentiary
support.
4. The evidence must be substantial.
o “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.”
o Mere uncorroborated hearsay or rumor does not
constitute substantial evidence.
5. The decision must be rendered on the evidence presented, or
at least contained in the record and disclosed to the parties
affected.
o 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.
o 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.
o The Court of Industrial Relations may refer any
industrial or agricultural dispute of any matter under
its consideration or advisement to a local board of
inquiry, a provincial fiscal, a justice of the peace, or
any public official in any part of the Philippines for
investigation, report, and recommendation.
6. The tribunal or any of its judges must act on its or his own
independent consideration of the law and facts of the
controversy. It may not simply accept the views of a
subordinate in arriving at a decision.
7. The tribunal must render its decision in such a manner that
the parties can know the various issues involved and the
reasons for the decision rendered.

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 The Court of Industrial Relations
 The Court of Industrial Relations is a special court whose functions
are specifically stated in the law of its creation (Commonwealth Act
No. 103). It is more an administrative board than a part of the
integrated judicial system of the nation.
 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 is more active, affirmative, and dynamic.

o It not only exercises judicial or quasi-judicial functions in

the determination of disputes between employers and
employees; its functions are far more comprehensive and
extensive.

o 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 landlords and
tenants or farm-laborers, and regulate the relations
between them, subject to, and in accordance with, the
provisions of Commonwealth Act No. 103 (section 1).

o It shall take cognizance for purposes of prevention,

arbitration, decision and settlement, of any industrial or
agricultural dispute causing or likely to cause a strike or
lockout, arising from differences as regards wageshares
or compensation, hours of labor or conditions of tenancy
or employment, between employers and employees or
laborers and between landlords and tenants or farm-
laborers, provided that the number of employees,
laborers or tenants or farm-laborers involved exceeds
thirty, and such industrial or agricultural dispute is
submitted to the Court by the Secretary of Labor or by
any or both of the parties to the controversy and certified
by the Secretary of Labor as existing and proper to be
death with by the Court for the sake of public interest.

o It may appeal to voluntary arbitration in the settlement of

industrial disputes; may employ mediation or conciliation
for that purpose, or recur to the more effective system of
official investigation and compulsory arbitration in order to
determine specific controversies between labor and
capital in industry and in agriculture. There is in reality
here a mingling of executive and judicial functions, which
is a departure from the rigid doctrine of the separation of
governmental powers.

CONCLUSION/HOLDING:

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The motion for new trial filed by the National Labor Union should be granted. The case should be remanded to the Court
of Industrial Relations for reception of evidence, so that the National Labor Union could prove that Toribio’s allegation of
leather shortage was false.

DISPOSITIVE: 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.
AI

SEPARATE OPINION:

JAVIER - LAW 172, PROF. LOANZON