Scribd
Upload
516 views2 pages

Ang Tibay Vs CIR

The Supreme Court granted the National Labor Union's request for a new trial in the case of Ang Tibay vs CIR. The NLU provided newly discovered evidence that was inaccessible during the initial trial, including Ang Tibay's business records, that was of such importance that it would necessarily require reversing the previous judgment. While administrative bodies like the CIR are not strictly bound by court rules, they must still comply with due process requirements like allowing parties to present evidence, considering all evidence presented, having substantive evidence to support decisions, rendering decisions based solely on the record, and providing reasoning for decisions.

Uploaded by

Nyx Perez
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
516 views2 pages

Ang Tibay Vs CIR

The Supreme Court granted the National Labor Union's request for a new trial in the case of Ang Tibay vs CIR. The NLU provided newly discovered evidence that was inaccessible during the initial trial, including Ang Tibay's business records, that was of such importance that it would necessarily require reversing the previous judgment. While administrative bodies like the CIR are not strictly bound by court rules, they must still comply with due process requirements like allowing parties to present evidence, considering all evidence presented, having substantive evidence to support decisions, rendering decisions based solely on the record, and providing reasoning for decisions.

Uploaded by

Nyx Perez
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

ANG TIBAY vs CIR

G.R. No. L-46496, February 27, 1940

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 layoff 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 Worker’s 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.

You might also like