Beruflich Dokumente
Kultur Dokumente
Office of the Solicitor-General Ozaeta and Assistant Attorney Barcelona for the
Court of Industrial Relations.
Antonio D. Paguia for National Labor Unon.
Claro M. Recto for petitioner "Ang Tibay".
Jose M. Casal for National Workers' Brotherhood.
LAUREL, J.:
EN BANC, G.R. No. L-46496, February 27, 1940, 69 Phil 635
Facts:
Ang Tibay is a leather company which supplies the Philippine Army before World
and is operated and managed by Teodorio Toribio. Toribio claimed that there
was shortage of leather soles making it necessary for him to layoff employees.
However, the National Labor Union (NLU) claim that Toribio only dismissed their
members and favoring another union group the National Workers Brotherhood Union
which they say is a company union dominated by Toribio, an unfair labor practice.
The Court of Internal Relations (CIR) elevated the case to the Supreme Court.
The Supreme Court ruled in favor of Ang Tibay thus the Solicitor General filed
its motion for reconsideration and the NLU filed for a motion for new trial.
NLU submitted new evidence which have been inaccessible to them before, the
importance of which are far-reaching and the admission would necessarily mean
the modification and reversal of the judgment.
Issue:
Were procedural lapses committed by the CIR worthy of reconsideration and new
trial?
Ruling/Decision:
Supreme Court deem it not necessary to pass upon the motion for reconsideration
but , in the interest of justice, grant the NLU’s motion for new trial.
The Supreme Court noted the following observations regarding the nature of the
powers of the Court of Industrial Relations:
1. The Court of Industrial Relations is a special court whose functions are
specifically stated in the law of its creation (Commonwealth Act No. 103). It
is more an administrative than a part of the integrated judicial system of the
nation. It is not intended to be a mere receptive organ of the Government. Unlike
a court of justice which is essentially passive, acting only when its
jurisdiction is invoked and deciding only cases that are presented to it by the
parties litigant, the function of the Court of Industrial Relations, as will
appear from perusal of its organic law, is more active, affirmative and dynamic.
It not only exercises judicial or quasi-judicial functions in the determination
of disputes between employers and employees but its functions in the
determination of disputes between employers and employees but its functions are
far more comprehensive and expensive. It has jurisdiction over the entire
Philippines, to consider, investigate, decide, and settle any question, matter
controversy or dispute arising between, and/or affecting employers and employees
or laborers, and regulate the relations between them, subject to, and in
accordance with, the provisions of Commonwealth Act No. 103 (section 1).
There are primary rights which must be respected even in proceedings of this
character:
(1) The first of these rights is 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.
(4) Not only must there be some evidence to support a finding or conclusion
but the evidence must be "substantial." It means such relevant evidence as a
reasonable mind 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. Only
by confining the administrative tribunal to the evidence disclosed to the
parties, can the latter be protected in their right to know and meet the case
against them.
(6) The Court of Industrial Relations 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. It may be that the volume of work is such that it is literally
Relations personally to decide all controversies coming before them.