Ang Tibay vs. CIR (G.R. No.

L-46496)

Facts:
Ang Tibay was a manufacturer of rubber slippers. There was a shortage of leather soles, and it was necessary to temporarily lay off
members of the National Labor Union. According to the Union however, this was merely a scheme to systematically terminate the
employees from work, and that the shortage of soles is unsupported. It claims that Ang Tibay is guilty of unjust labor practice
because the owner, Teodoro, is discriminating against the National Labor Union, and unjustly favoring the National Workers
Brotherhood, which was allegedly sympathetic to the employer. The Court of Industrial Relation decided the case and elevated it to
the Supreme Court, but a motion for new trial was raised by the NLU. But the Ang Tibay filed a motion for opposing the said motion.

The motion for new trial was raised because according to NLU, there are documents that are so inaccessible to them 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. That these documents, which NLU have now attached as exhibits are of such far-reaching importance and effect that their
admission would necessarily mean the modification and reversal of the judgment rendered therein.

Issue:
WON the union was denied due process by CIR.

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.

SC had the occasion to point out that the CIR is not narrowly constrained by technical rules of procedure, and equity and substantial
merits of the case, without regard to technicalities or legal forms and shall not be bound by any technical rules of legal evidence but
may inform its mind in such manner as it may deem just and equitable.

The fact, however, that the CIR may be said to be free from 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. 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 one's 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.

SC said there was a failure to grasp the fundamental issue involved due to failure to receive all relevant evidence. Thus, the motion
for a new trial was granted and the entire record of this case is remanded to the CIR.
Montemayor v Araneta university

Facts: Felix Montemayor was a faculty of Araneta University Foundation serving as Head of Humanities
and Psychology Department. The Chaplain filed a complaint of immorality against him. A committee was
created to investigate the allegation. With the assistance of counsel, he filed a motion to dismiss or to hold
the hearing in abeyance. The committee found him responsible of the act complained of and
recommended for his demotion by one degree. The President adopted such recommendation and
thereafter referred the same to the Board of Trustees of private respondent for appropriate action.
Subsequently new charges was filed by different faculty members against him and a new committee was
formed to investigate the allegations. Montemayor asked for postponement of the hearing and was
denied. The hearing proceeded without him and found him guilty of the same charges and recommended
for the discontinuance of his service. He then filed a complaint with NLRC. NLRC decided in favour of the
Foundation. Hence the present petition.

Issue: Whether or not the proceeding relating to Montemayor’s dismissal was done in violation of due
process?

Decision: Petition dismissed. In Montemayor’s absence the matter was heard and was sufficiently found
by the committee to be guilty of his conduct unbecoming and recommended his removal. Such deficiency
was remedied when Montemayor was able to present his case with the Labour Commission. Records will
show that after all efforts on conciliation had failed parties agreed to submit their dispute for compulsory
arbitration. Several hearings were conducted. he legal aspect as to the procedural due process having
been satisfied was then summarized by the Solicitor General thus: “All the foregoing clearly shows that
petitioner was afforded his day in court. Finally, and more significant, is the fact that petitioner claims
denial of due process in the proceeding had before the investigating committees and not in the
proceedings before the NLRC wherein, as shown heretofore, he was given the fullest opportunity to
present his case.