REQUIREMENTS

33. ANG TIBAY V. CIR, 69 PHIL. 635

Facts:
Ang TIbay was a manufacturer of rubbers slippers. There was a shortage of
leather soles, and it was necessary to temporarily lay off members of the National
Labor Union (NLU). The respondent National Labor Union, Inc. avers that: (1) Toribio
Teodoro, who is the manager and proprietor of Ang Tibay, was falsely claiming that
there is a shortage of leather soles for him to temporarily lay off the Members of the
National Labor Union, Inc. as it was unsupported byrecords; (2) the alleged lack of
materials was a scheme to discharge systematically the Membersof the NLU, Inc.
from work; (3) The National Workers Brotherhood of Ang Tibay is an illegal
unionwhich is dominated by Toribio Teodoro; and that (4) The employer, Toribio
Teodoro, was guilty of unfair labor practice for discriminating against the NLU, Inc,
and unjustly favoring the NationalWorkers Brotherhood.The Court of Industrial
Relation decided the case and elevated it to the Supreme Court, but a motion for
new trial was raised by the NLU but the Ang Tibay filed a motion for opposing the
said motion. The case enumerated the specific powers of the Court of Industrial
Relations. The CIR, as the Court observed is not constrained by technical rules of
procedure in hearing the matters before it, but it does not mean that it can ignore
entirely the fundamental and essential requirements of due process in trials
and investigations of an administrative character.
Issue: WON the union was denied due process by CIR.
Ruling: Yes. SC said that there was 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 Court of Industrial
Relations, 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.
The Court provided the ff. as the requisites of procedural due process in
administrative proceedings:
1. The right to a hearing, which includes the right to present ones case and submit
evidence in support thereof.
2. Tribunal must consider the evidence presented.
3. Decision must have something to support it.
4. Evidence must be substantial (more than a mere scintilla, relevant evidence a
reasonable mind accepts to support a conclusion)
5. Decision must be rendered on the evident presented at the hearing, or at least
contained in the record or disclosed to the parties affected.
6. Tribunal or body or any of its judges 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. The board or body 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 reason for the decision rendered