Case # 11

Ang Tibay v. CIR

FACTS: Teodoro Toribio owns and operates Ang Tibay, a leather company which supplies the Philippine Army.
Due to alleged shortage of leather, Toribio caused the lay off of a number of his employees. However, the National
Labor Union, Inc. (NLU) questioned the validity of said lay off as it averred that the said employees laid off were
members of NLU while no members of the rival labor union (National Workers Brotherhood) were laid off. NLU
claims that NWB is a company dominated union and Toribio was merely busting NLU.

The case reached the Court of Industrial Relations (CIR) where Toribio and NWB won. Eventually, NLU went to
the Supreme Court invoking its right for a new trial on the ground of newly discovered evidence. The Supreme
Court agreed with NLU. The Solicitor General, arguing for the CIR, filed a motion for reconsideration.

ISSUE: Whether or not the National Labor Union, Inc. is entitled to a new trial.

HELD: Yes. The records show that the newly discovered evidence or documents obtained by NLU, which they
attached to their petition with the SC, were evidence so inaccessible to them at the time of the trial 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. Further, 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 (said newly
obtained records include books of business/inventory accounts by Ang Tibay which were not previously accessible
but already existing).

The SC also outlined that administrative bodies, like the CIR, although not strictly bound by the Rules of Court
must also make sure that they comply to the requirements of due process. For administrative bodies, due process
can be complied with by observing the following:

(1) The 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) Not only must the party be given an opportunity to present his case and to adduce evidence tending to
establish the rights which he asserts but the tribunal must consider the evidence presented.

(3) While the duty to deliberate does not impose the obligation to decide right, it does imply a necessity which
cannot be disregarded, namely, that of having something to support its decision. A decision with absolutely nothing
to support it is a nullity, a place when directly attached.

(4) Not only must there be some evidence to support a finding or conclusion but the evidence must be
substantial. Substantial evidence is more than a mere scintilla It means such relevant evidence as a reasonable
mind might accept 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.

(6) The administrative body 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.

(7) The administrative 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 reasons for the decisions rendered. The
performance of this duty is inseparable from the authority conferred upon it.