The CIR ruled against NLU in a labor dispute between Ang Tibay and NLU. NLU appealed, arguing there were due process violations. The Supreme Court ruled that while CIR is not bound by technical rules, it must still follow fundamental due process requirements. It granted NLU's request for a new trial, finding CIR did not properly consider evidence presented and its decision was not adequately explained. The case was remanded to CIR to reopen proceedings, receive all relevant evidence, and issue a new ruling in line with due process.
The CIR ruled against NLU in a labor dispute between Ang Tibay and NLU. NLU appealed, arguing there were due process violations. The Supreme Court ruled that while CIR is not bound by technical rules, it must still follow fundamental due process requirements. It granted NLU's request for a new trial, finding CIR did not properly consider evidence presented and its decision was not adequately explained. The case was remanded to CIR to reopen proceedings, receive all relevant evidence, and issue a new ruling in line with due process.
The CIR ruled against NLU in a labor dispute between Ang Tibay and NLU. NLU appealed, arguing there were due process violations. The Supreme Court ruled that while CIR is not bound by technical rules, it must still follow fundamental due process requirements. It granted NLU's request for a new trial, finding CIR did not properly consider evidence presented and its decision was not adequately explained. The case was remanded to CIR to reopen proceedings, receive all relevant evidence, and issue a new ruling in line with due process.
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