Professional Documents
Culture Documents
CIR
ANG TIBAY and NATIONAL WORKERS BROTHERHOOD v. COURT OF INDUSTRIAL RELATIONS
and NATIONAL LABOR UNION, INC.
27 February 1940 | Laurel
Decision on motion for reconsideration and on motion for new trial
Facts
An MfR was filed by the Solicitor-General on behalf of respondent CIR. National Labor Union on the other
hand prays for the remanding of the case to CIR for a new trial. Ang Tibay filed an opposition for both the
motion for reconsideration of CIR and the motion for a new trial by the National Labor Union (NLU).
Toribio Teodoro owns and operates Ang Tibay, a leather company which supplies the Philippine Army. NLU
avers that employer Toribio Teodoro (of the National Workers Brotherhood [NWB] of Ang Tibay) made a
false claim that there was a shortage of leather soles in Ang Tibay, making it necessary for him to lay off
workers. 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 NWB.
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.
MfR denied. Motion for new trial granted. Case remanded to CIR.
Characterization of CIR
HOWEVER, 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.
1. Right to a hearing, including the right to present ones own case and submit evidence in support
thereof
2. Tribunal must consider the evidence presented
3. Decision must have something to support itself
4. Evidence must be substantial
1. It must be relevant as a reasonable mind might accept it as adequate to support a conclusion
2. The rules of evidence shall not be controlling so that the mere admission of matter which
would be deemed incompetent in judicial proceedings would not invalidate the administrative
order
3. Mere uncorroborated hearsay or rumor does NOT constitute substantial evidence
5. Decision must be rendered on the evidence presented at the hearing, or at least contained in the
record and disclosed to the parties affected
1. On boards of inquiry
1. They may be appointed for the purpose of investigating and determining the facts in
any given case
2. Their report and decision are only advisory
3. CIR may refer any industrial or agricultural dispute to a board of inquiry, fiscal, justice
of the peace, any public official but such delegation shall not affect the exercise of the
Court itself or any of its powers
6. CIR 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 in arriving at the decision
7. CIR should render its decision in such a manner that the parties can know the issues involved and the
reasons for the decisions rendered.