ANG TIBAY vs CIR (ADMINISTRATIVE LAW)

G.R. No. L-46496             February 27, 1940

ANG TIBAY, represented by TORIBIO TEODORO, manager and propietor, and 

NATIONAL WORKERS BROTHERHOOD, petitioners, 

vs.

THE COURT OF INDUSTRIAL RELATIONS and NATIONAL LABOR UNION, INC., respondents.

Office of the Solicitor-General Ozaeta and Assistant Attorney Barcelona for the Court of Industrial Relations.

Antonio D. Paguia for National Labor Unon.

Claro M. Recto for petitioner "Ang Tibay".

Jose M. Casal for National Workers' Brotherhood.

LAUREL, J.:

FACTS:

The respondent National Labor Union, Inc., prays for the vacation of the judgement rendered by the majority of this Court and the remanding of the case to the Court of Industrial Relations for a new trial, and avers:

That Toribio Teodoro's claim that on September 26, 1938, there was shortage of leather soles in ANG TIBAY making it necessary for him to temporarily lay off the members of the National Labor Union Inc., is entirely false and unsupported by the records of the Bureau of Customs and the Books of Accounts of native dealers in leather. That the supposed lack of leather materials claimed by Toribio Teodoro was but a scheme to systematically prevent the forfeiture of this bond despite the breach of his CONTRACT with the Philippine Army.

ISSUE:

Whether the case should be set for new trial.

RULING:

The CIR is free from rigidity of certain procedural requirements, but this 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.

The failure to grasp the fundamental issue involved is not entirely attributable to the parties adversely affected by the result. 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 CIR, 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.