Ang Tibay Ang Tibay v. CIR CIR Constitutional Law Constitutional Law 2 Digest
Ang Tibay Ang Tibay v. CIR CIR Constitutional Law Constitutional Law 2 Digest
Ang Tibay Ang Tibay v. CIR CIR Constitutional Law Constitutional Law 2 Digest
CIR
Tags: ang tibay, ang tibay v. CIR, CIR, constitutional law, constitutional law 2, digest
ANG TIBAY and NATIONAL WORKERS BROTHERHOOD v. COURT OF INDUSTRIAL RELATIONS and NATIONAL LABOR
UNION, INC.
27 February 1940 | Laurel
Decision on motion for reconsideration and on motion for new trial
Facts
An MfR was filed by the Solicitor-General on behalf of respondent CIR. National Labor Union on the other hand prays for the
remanding of the case to CIR for a new trial. Ang Tibay filed an opposition for both the motion for reconsideration of CIR and the
motion for a new trial by the National Labor Union (NLU).
Toribio Teodoro owns and operates Ang Tibay, a leather company which supplies the Philippine Army. NLU avers that employer
Toribio Teodoro (of the National Workers Brotherhood [NWB] of Ang Tibay) made a false claim that there was a shortage of leather
soles in Ang Tibay, making it necessary for him to lay off workers. NLU alleges that such claim was unsupported by the Bureau of
Customs records and the accounts of native dealers of leather. Such was just a scheme adopted to discharge all the members of
the NLU from work. Hence, they say that Teodoro was guilty of unfair labor practice for discriminating against NLU and unjustly
favoring NWB.
As regards the exhibits attached to this case, NLU says that these are so inaccessible to the respondents that even with the
exercise of due diligence they could not be expected to have obtained them and offered as evidence in the CIR. In addition, the
attached documents and exhibits are of such far-reaching importance and effect that their admission would necessarily mean the
modification and reversal of the judgment rendered herein.
MfR denied. Motion for new trial granted. Case remanded to CIR.
Characterization of CIR
Special court whose functions are stated in CA No. 103
More of an administrative board than a part of the integrated judicial system
Function is more active, affirmative, dynamic
Exercises judicial / quasi-judicial functions in the determination of disputes between employers and employees
Has jurisdiction over the entire PH re: matters concerning employer-employee, landlord-tenant/farm-laborer relations
Can take cognizance of industrial or agricultural dispute causing or likely to cause a strike or lockout provided that
o The number of employees involved exceeds 30
o Such dispute is submitted to the Court by the Labor Sec. or by any / both of the parties to the controversy and
certified by Labor Sec. as proper to be dealt with by the court
Investigates and studies all pertinent facts related to the industry concerned when directed by the PH President
There is a mingling of executive and judicial functions, a departure from the rigid doctrine of the separation of governmental
powers
In Goseco v. CIR, the Court said that CA 103 requires CIR to act according to justice and equity and substantial merits of the case,
without regard to technicalities or legal forms and shall not be bound by any 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.
HOWEVER, this does NOT mean that CIR can entirely ignore or disregard the fundamental and essential requirements of due
process in trials and investigations of an administrative character.