Case Title Ang Tibay vs.

Court of Industrial Relations

G.R. no. 46496
Main Topic Due Process
Other Related Topic Technical Rules of Procedure; Court of Industrial Relations
Date: February 27, 1940

DOCTRINES

1. COURT OF INDUSTRIAL RELATIONS; POWER; 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. It is not a mere receptive organ of the
Government. The function of the Court of Industrial Relations, 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 employee 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 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).

2. TECHNICAL RULES OF PROCEDURE; DUE PROCESS OF LAW; The Court of

Industrial Relations is not narrowly constrained by technical rules of procedure, and
Commonwealth Act No. 103 requires it to act according to justice and equity and
substantial merits of the case, without regard to technicalities or legal evidence but may
inform its mind in such manner as it may deem just and equitable. The fact, however, that
the Court of Industrial Relations may be said to be free from the 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.

3. CARDINAL PRIMARY RIGHTS; There are cardinal primary rights which must be
respected even in proceedings of this character:

a. 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.
“The liberty and property of the citizen shall be protected by the rudimentary
requirements of fair play.”

b. 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.
 c. “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. A decision with absolutely nothing to support it is a nullity, a
place when directly attached.” This principle emanates from the more fundamental
principle that the genius of constitutional government is contrary to the vesting of
unlimited power anywhere. Law is both a grant and a limitation upon power.

d. Not only must there be some evidence to support a finding or conclusion, but the
evidence must be “substantial.” “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.”

FACTS:

ANG TIBAY; Represented by TORIBIO TEODORO manager and proprietor;Petitioners,

temporarily laid-off 89 members of the National Labor Union Inc., due to the shortage of leather
soles.

Petitioner filed an opposition both to the motion for reconsideration of the respondent Court of
Industrial Relations and to the motion for new trial of the respondent National Labor Union Inc.

NATIONAL LABOR UNION INC.; Respondent, avers the claim of Toribio that there was a
shortage of leather soles on September 26, 1938; That the supposed lack of leather materials
claimed by Teodoro Toribio was but a scheme adopted to systematically discharge all the
members of the National Labor Union Inc., from work.

The averment of National Labor Unions Inc. is desired to be proved by the petitioner with the
“records of the Bureau of Customs and the Books of Accounts of native dealers in leather”; that
“the National Workers’ Brotherhood Union of Ang Tibay is a company or employer union
dominated bny Toriobio Teodoro, the existence and functions of which are illegal.”

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. It is not a mere receptive organ of the
Government. The function of the Court of Industrial Relations, 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 employee but its
functions are far more comprehensive and extensive.”

ISSUE:

Whether or not the Court of Industrial Relations has the power of due process?

HELD:
Yes. The Court of Industrial Relations can administer due process. “The Court of Industrial
Relations is a special court whose functions are specifically stated in the law of its creation
(Commonwealth Act No. 103).

The motion for reconsideration of the Solicitor-General in-behalf of the respondent Court of
Industrial Relations denied.

The motion for a new trial granted and cause remanded with instructions.