Ang Tibay vs CIR, 69 Phil 635

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 members of National Labor Union (NLU). NLU averred that Toribios act is not valid.
The CIR, decided the case and elevated it to the SC, but a motion for new trial was raised by the NLU. But Ang Tibay filed a motion
for opposing the said motion.
Issue: What is the function of CIR as a special court?
Held: To begin with the issue before us is to realize the functions of the CIR. The CIR is a special court whose functions are
specifically stated in the law of its creation which is the Commonwealth Act No. 103). It is more an administrative board 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 CIR, 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 are far more comprehensive and extensive. It has jurisdiction over the entire Philippines, to consider,
investigate, decide, and settle any question, matter controversy or disputes arising between, and/ or affecting employers and
employees or laborers, and landlords and tenants or farm-laborers, and regulates the relations between them, subject to, and in
accordance with, the provisions of CA 103.
The CIR is free from rigidity of certain procedural requirements, but this 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. There are cardinal primary rights which must be respected even in proceedings of this character:
(1) the right to a hearing, which includes the right to present ones cause and submit evidence in support thereof;
(2) The tribunal must consider the evidence presented;
(3) The decision must have something to support itself;
(4) The evidence must be substantial;
(5) The decision must be based on the evidence presented at the hearing; or at least contained in the record and disclosed to the
parties affected;
(6) The tribunal or body or any of its judges must act on its own independent consideration of the law and facts of the
controversy, and not simply accept the views of a subordinate;
(7) The Board or body should, in all controversial questions, render its decision in such manner that the parties to the proceeding
can know the various Issue involved, and the reason for the decision rendered.
The failure to grasp the fundamental issue involved is not entirely attributable to the parties adversely affected by the result.
Accordingly, the motion for a new trial should be, and the same is hereby granted, and the entire record of this case shall be
remanded to the CIR, with instruction that it reopen the case receive all such evidence as may be relevant, and otherwise proceed
in accordance with the requirements set forth.
National Liga ng mga Barangay vs. Paredes, 439 SCRA 130
(Admin Law, DILG-Liga ng mga Barangay, quasi-legislative power)
Facts: DILG, appointed as interim caretaker to administer and manage the affairs of the Liga ng mga Barangay in giving remedy
to alleged violations made by the incumbent officer of the Liga in the conduct of their elections, issued 2 memorandum circulars
which alter, modify, nullify or set aside the actions of the Liga.
Petitioner contends that DILGs appointment constitutes undue interference in the internal affairs of the Liga, since the latter is
not subject to DILG control and supervision. Respondent judge contends that DILG exercises general supervisory jurisdiction over
LGUs including the different leagues based on sec. 1 of Admin. Order No. 267 providing for a broad premise of the supervisory
power of the DILG.
Issue: WON DILG Secretary as alter-ego of the President has power of control over the Liga ng mga Barangay.
Held: No. Sec. 4, Art. X of the Constitution provides that the President of the Philippines shall exercise general supervision over
local government, which exclude the power of control. As the entity exercising supervision over the Liga, the DILGs authority is
limited to seeing to it that the rules are followed, but it cannot lay down such rules itself nor does it have the discretion to modify
or replace the same.
Phil. Association of Service Exporters, Inc. vs. Torres, 212 SCRA 298; G.R. No. 101279, August 6, 1992
(Admin Law, DOLE, quasi-legislative power)
Facts: DOLE Dept. Order No. 16 temporarily suspends the recruitment by private employment agencies of Filipino DH going to
Hong Kong in view of the need to establish mechanisms that will enhance the protection for the same.
The DOLE, through POEA took over the business of deploying such HK-bound workers. Pursuant to the above order, POEA issued
memorandum circular no. 30 providing guidelines on the government processing and deployment of Filipino domestic helpers to
HK and the accreditation of HK recruitment agencies intending to hire Filipino domestic helpers, and the memorandum circular No.
30, pertaining to the processing of employment contracts of domestic workers for HK.
Petitioner contends that respondents acted with grave abuse of discretion and/or in excess of their rule-making authority in
issuing said circulars.
Issue: WON the take-over of the business deploying DH to HK by DOLE and POEA through an administrative order and circular is
valid.

Held: Yes. Article 36 of the Labor Code grants the Labor Secretary the power to restrict and regulate recruitment and placement
activities. The challenge administrative issuance discloses that the same fall within the administrative and police powers
expressly or by necessary implication conferred upon the respondents.