Ang Tibay vs CIR

69 Phil 635

(Admin Law, CIR)

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.