Ang Tibay v. The Court of Industrial Relations

G.R. No. 46496
February 27, 1940

Facts

Respondent Court of Industrial Relations filed a motion for consideration on the decision of the Supreme Court. On the other hand, 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. On the other hand, the petitioner Ang Tibay filed their opposition to both.

Respondent alleged that that “the supposed lack of leather material claimed by Toribio Teodoro was but a scheme adopted to systematically discharge all the members of the National Labor Union, Inc., from work” and this averment 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 by Toribio Teodoro, the existence and functions of which are illegal.” On the other hand, petitioner alleges under oath that the exhibits attached to the petition to prove his substantial averments “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”, and that the documents attached to the petition “are of such far reaching importance and effect that their admission would necessarily mean the modification and reversal of the judgment rendered therein.”

Issue

Whether or not a new trial be granted in order that the respondent can present other evidence to support their claim even though the Supreme Court has already decided on the issue?

Held

Yes. In Goseco v Court of Industrial Relations, the Supreme Court held that the Court of Industrial Relations(CIR) is not narrowly constrained by the technical rules of procedure whereas Commonwealth Act No 103 requires CIR to act according to justice, equity, and substantial merits of the case without regards to the technicalities or the legal forms as well as the legal rules of evidence. However, the Supreme Court stressed that the freedom from procedural rigidity does not mean that the Court of Industrial Relations will entirely ignore or disregard the fundamental and essential requirements of due process in trials and investigations of administrative character.

The Supreme Court also enumerated the cardinal primary rights which must be respected in administrative proceedings as follows:

Due Process in Administrative Proceedings

1. Right to hearing (the right of the party to present his own case and submit evidence)
2. The tribunal must consider the evidence presented
3. The duty to deliberate imply the necessity of having something to support the decision. A decision without absolutely nothing to support it is a nullity.
4. Evidence must be substantial (relevant evidence as a reasonable mind might accept as adequate to support its 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. (To protect the right of the parties to know and meet the case upon them)
6. Courts 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.
7. Courts 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 decisions rendered.

In view of the foregoing, it is observed in the case that the record is barren and does not satisfy the thirst for a factual basis upon which to predicate a conclusion of a law in a rational way.

Hence, for the interest of justice, the motion for new trial is granted which gives the opportunity to present at the hearing the documents referred to by the respondent and such other evidence as may be relevant to the main issue involved.