Ang Tibay vs.

CIR
69 Phil 635; G.R. No. 46496; 27 Feb. 1940

Facts:

Petitioner claimed that there was shortage of leather soles in ANG TIBAY making it necessary
for him to temporarily lay off the workers from the National Labor Union Inc.

National Labor Union, Inc. (NLU) questioned the validity of said lay off. They contend: (1) that
the lack of leather materials as claimed by Teodoro was only a scheme to prevent the forfeiture
of this bond despite the breach of his contract with the Philippine Army; (2) National Worker's
Brotherhood of ANG TIBAY is a company or employer union dominated by Teodoro, the
existence and functions of which are illegal; (3) That in the exercise by the laborers of their
rights to collective bargaining is indispensable;(4) Civil code shouldnt be used to interpret a
legislation of American industrial origins. (5) That the employer Teodoro was guilty of unfair labor
practice for favoring the National Workers' Brotherhood.

Issue:

Whether or not the Court of Industrial Relations is a proper venue for trial

Ruling:

The Court of Industrial Relations is a special court whose functions are specifically stated in the
law of its creation (Commonwealth Act No. 103) It not only exercises judicial or quasi-judicial
functions in the determination of disputes between employers and employees but its functions in
the determination of disputes between employers and employees.

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.