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Case Digest:

ANG TIBAY VS. COURT OF INDUSTRIAL RELATIONS (CIR)

[69 PHIL 635; G.R. NO. 46496; 27 FEB 1940]

Facts:

ANG TIBAY is a company owned and controlled by one Toribio Teodoro. ANG TIBAY

has two major labor unions. The first one is the National Workers Brotherhood, which is an

employer union alleged to be dominated by Teodoro. The second one is the National Labor

Union Inc, which is a union dominated by the laborers of ANG TIBAY. The laborers sought to

have a Collective Bargaining Agreement with ANG TIBAY. Teodoro felt it necessary to

temporarily dismiss some 89 employees, particularly members of the National Labor Union

Inc. He used the shortage of leather soles in ANG TIBAY as a reason for such act.

ANG TIBAY had a contract, secured by a bond, with the Philippine Army. This

contract was breached by ANG TIBAY. The former used the supposed delay of leather soles

from the United States as an excuse for the non-compliance with the said contract. This

resulted to a case between ANG TIBAY and the aggrieved labor union. ANG TIBAY won in

the Supreme Court.

After the SC ruling, there were two Motions for Reconsideration submitted by the

Solicitor General, in behalf of the Court of Industrial Relations (CIR); and the National Labor

Union (NLU), Inc. The latter MR submitted by the union wants the case to be reopened for

several reasons, among these are:

a. The new exhibits they attached are so inaccessible to the respondents that evenwith the exercise of due diligence they could not be expected to have obtained

them and offered as evidence in the Court of Industrial Relations; and

b. The attached documents and exhibits are of such far-reaching importance andeffect that their admission would necessarily mean the modification and reversal

of the judgment rendered by the Supreme Court.

ANG TIBAY, represented by its manager, Teodoro, then filed an opposition for the MR.

Issue/s:

Whether or not there has been a due process of law and whether or not the motion

for a new trial of the respondent labor union should be granted by the Court.

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Held:

The Supreme Court that the motion for reconsideration filed by the Solicitor-General

in behalf of the CIR is not valid. However, the Court granted the second MR, ruling that

there has not been a due process of law and that there should be a new trial in favor ofNLU. According to the Supreme Court, all administrative bodies cannot disregard the seven

fundamental and essential requirements of due process, which are:

1. The right to a hearing, which includes the rights of the party interested topresent his own case and submit evidence in support thereof.

2. The tribunal must consider the evidence presented.3. The decision must have something to support it.4. The evidence must be substantial.5. The decision must be rendered on the evidence presented or at least contained

in the records and disclosed to the parties.

6. The judge must act on its or his own independent consideration of the law andfacts of the controversy, and not simply accept the views of a subordinate in

arriving at a decision.

7. It should render its decision in such a manner that the parties to the proceedingscan know the various issues involved.