Administrative Due Process
Ang Tibay v. CIR The court provided the ff. As the requisites of
69 Phil 635
February 27, 1940
Facts:
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 by records, (2) the alleged lack of
materials was a scheme to discharge
systematically the Members of the NLU, Inc.
From work; (3) The National Workers’
Brotherhood of Ang Tibay is an illegal union
which is dominated by Toribo Teodoro; and that
(4) The employer, Toribio Teodoro, was guilty of
unfair labor practice for discriminating against
the NLU, Inc, and unjustly favouring the
National Workers’ Brotherhood.
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.
Issues:
What are the cardinal rights or the requisites of
procedural due process which must be
respected in administrative proceedings?
HELD:
procedural due process in administrative
proceedings:
1. The right to a hearing, which includes
the right to present one’s 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
evidence presented at the hearing, or at
least contained in the record or
disclosed to the parties affected.
6. Tribunal or body or any 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 the 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 preceding can know the various
issued involved, and the reason for the
decision rendered.