Topic: Due Process
(With a shorter version at the latter part)
G.R. No. L-46496 February 27, 1940
ANG TIBAY, represented by TORIBIO TEODORO, manager and propietor, and
NATIONAL WORKERS BROTHERHOOD, petitioners,
vs.
THE COURT OF INDUSTRIAL RELATIONS and NATIONAL LABOR UNION,
INC., respondents.
Facts:
The Solicitor General in behalf of the respondent Court of Industrial Relations has filed a
motion for reconsideration wherein the court has considered the legal conclusions
stated in Spanish language.
The respondent National Labor Union, Inc., on the other hand, prays for the vacation of
the judgment of the majority of this court and remanded the case to the Court of
Industrial Relations for new trial averring among other issues that Toribio Teodoro
claimed that there was shortage of Ang Tibay leather shoes thus it made him necessary
to lay off the members of the National Labor Union, Inc.
That the supposed lack of leather materials claimed by Toribio Teodoro was but a
scheme to systematically prevent the forfeiture of this bond despite the breach of his
contract with the Philippine Army.
That the employer Toribio Teodoro was guilty of unfair labor practice for discriminating
against the National Labor Union, Inc. and unjustly favoring the National Workers’
Brotherhood.
The exhibits 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.
Issue:
Whether or not the motion for new trial should be granted for the movant to present at
the hearing the documents referred to in his motion.
Held:
Yes. The motion for a new trial should granted, and the entire record of this case shall
be remanded to the Court of Industrial Relations
The Court of Industrial Relations is not narrowly constrained by technical rules of
procedure, and Commonwealth Act No. 103 requires it to act according to justice and
equity and substantial merits of the case, without regard to technicalities or legal
evidence but may inform its mind in such manner as it may deem just and equitable
(Goseco v. Court of Industrial Relations Et. Al., G. R. No. 46673). The fact, however,
that the Court of Industrial Relations may be said to be free from the rigidity of certain
procedural requirements does not mean that it can, in justiciable cases coming before it,
entirely ignore or disregard the fundamental and essential requirements of due process
in trials and investigations of an administrative character.
The Court came to the conclusion that the interest of justice would be better served if
the movant is given opportunity to present at the hearing the documents referred to in
his motion and such other evidence as may be relevant to the main issue involved.
Shorter Version:
Facts:
The Solicitor General in behalf of the respondent Court of Industrial Relations
has filed a motion for reconsideration wherein the court has considered the legal
conclusions stated in Spanish language.
The respondent National Labor Union, Inc., on the other hand, prays for the
vacation of the judgment of the majority of the court and the remanding of the case to
the Court of Industrial Relations (CIR) for new trial averring that exhibits 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.
Issue:
Whether or not the motion for new trial should be granted for the movant to
present at the hearing the documents referred to in his motion.
Held:
Yes. The motion for a new trial should granted, and the entire record of this case
shall be remanded to the Court of Industrial Relations
The Court of Industrial Relations may be said to be free from the rigidity of
certain procedural requirements does not mean that it can, in justiciable cases coming
before it, entirely ignore or disregard the fundamental and essential requirements of due
process in trials and investigations of an administrative character.
The Court came to the conclusion that the interest of justice would be better
served if the movant is given opportunity to present at the hearing the documents
referred to in his motion and such other evidence as may be relevant to the main issue
involved.