Ang Tibay vs CIR, 69 Phil 635

Posted by Pius Morados on November 13, 2011

(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 dfor 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.