Case Digest: ANG TIBAY VS. COURT OF INDUSTRIAL RELATIONS (CIR) [69 PHIL 635; G.R. NO.

46496; 27 FEB 1940] Facts: ANG TIBAY is a company owned and controlled by one Toribio Teodoro. ANG TIBAY has two major labor unions. The first one is the National Workers Brotherhood, which is an employer union alleged to be dominated by Teodoro. The second one is the National Labor Union Inc, which is a union dominated by the laborers of ANG TIBAY. The laborers sought to have a Collective Bargaining Agreement with ANG TIBAY. Teodoro felt it necessary to temporarily dismiss some 89 employees, particularly members of the National Labor Union Inc. He used the shortage of leather soles in ANG TIBAY as a reason for such act. ANG TIBAY had a contract, secured by a bond, with the Philippine Army. This contract was breached by ANG TIBAY. The former used the supposed delay of leather soles from the United States as an excuse for the non-compliance with the said contract. This resulted to a case between ANG TIBAY and the aggrieved labor union. ANG TIBAY won in the Supreme Court. After the SC ruling, there were two Motions for Reconsideration submitted by the Solicitor General, in behalf of the Court of Industrial Relations (CIR); and the National Labor Union (NLU), Inc. The latter MR submitted by the union wants the case to be reopened for several reasons, among these are: a. The new exhibits they attached 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 b. 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 by the Supreme Court. ANG TIBAY, represented by its manager, Teodoro, then filed an opposition for the MR.

Issue/s: Whether or not there has been a due process of law and whether or not the motion for a new trial of the respondent labor union should be granted by the Court.

Held: The Supreme Court that the motion for reconsideration filed by the Solicitor-General in behalf of the CIR is not valid. However, the Court granted the second MR, ruling that there has not been a due process of law and that there should be a new trial in favor of NLU. According to the Supreme Court, all administrative bodies cannot disregard the seven fundamental and essential requirements of due process, which are: 1. The right to a hearing, which includes the rights of the party interested to present his own case and submit evidence in support thereof. 2. The tribunal must consider the evidence presented. 3. The decision must have something to support it. 4. The evidence must be substantial. 5. The decision must be rendered on the evidence presented or at least contained in the records and disclosed to the parties. 6. The judge 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. It should render its decision in such a manner that the parties to the proceedings can know the various issues involved.