ANG TIBAY VS. CIR
FACTS:
Petitioner, Ang Tibay has filed an
opposition for both the motion for reconsideration of CIR and the motion for a
new trial by the National Labor Union.
The National Labor Union’s case: they alleged that Toribio Teodoro,
who dominated the National Workers’ Brotherhood of Ang Tibay,made a false claim
that there was a shortage of leather soles in ANg Tibay that made it necessary
for him to lay off workers, however, claim was unsupported by records of the
Bureau of Customs & the accounts of native dealers of leather. Such was
just a scheme adapted to systematically discharge all the members of the NLU,
inc., from work. · Unfair labor
practice for discriminating against the
National Labor Union, Inc., and
unjustly favoring the National Workers' Brotherhood.· That the exhibits hereto attached
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 Court of Industrial Relations.
That 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.
HELD:
motion for reconsideration denied,
motion for new trial granted.
Discussion of the Nature of the CIR
to emphasize certain guiding principles which should be observed in the trial
of cases brought before it. Court of Industrial Relations an administrative court - exercises judicial
or quasi-judicial functions in the determination of disputes between employers
and employees
- 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 regulate the relations between them, subject to, and
in accordance with, the provisions of Commonwealth Act No. 103 (section 1).
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.
In the case of Goseco
vs. Court of Industrial
Court of Industrial Relations is
not narrowly constrained by
technical rules of procedure, and the Act requires it to "act
according to justice and equity and substantial merits of the case, 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
evidence but may inform
its mind in such manner as it may deem just and
equitable." (Section 20,
Commonwealth Act No. 103.)
requirements of due process in trials and investigations of an administrative
character.
1. 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.
2. tribunal must consider the evidence presented.
3. have something to support the decision
4. evidence must be
"substantial." - such relevant evidence as a reasonable mind accepts as adequate to
support a conclusion."
5. 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. Only by confining the administrative
tribunal to the evidence disclosed to the parties, can the latter be protected
in their right to know and meet the case against them.
6. 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. It may be that the volume of work is such that
it is literally Relations personally to decide all controversies coming before
them.
7.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 decision rendered. The performance of this duty is
inseparable from the authority conferred upon it.
The court observed that, except as
to the alleged agreement between the Ang Tibay and the National Worker's
Brotherhood, the record is barren and does not satisfy the thirst for a factual
basis upon which to predicate, in a national way, a conclusion of law.
Therefore, in the interest of justice, a new trial should commence giving the
movant the opportunity to present new evidence.
