ANG TIBAY VS.

CIR
G.R. No. L-46496. February 27, 1940
Ponente: LAUREL, J.

Facts:
 The case of Ang Tibay v. Court of Industrial Relations was decided by the Supreme
Court of the Philippines on February 27, 1940.
 The petitioners in the case were Ang Tibay, represented by Toribio Teodoro, the
manager and proprietor, and the National Workers' Brotherhood.
 The respondents were the Court of Industrial Relations and the National Labor Union,
Inc.
 The Court of Industrial Relations is a special court with extensive powers, as stated in
Commonwealth Act No. 103.
 The court has jurisdiction over disputes between employers and employees, as well as
landlords and tenants.
 The court is not bound by technical rules of procedure and is required to act according
to justice and equity.

Issues:
 The main issue raised in the case is the violation of due process and the right to a fair
hearing.
 The petitioners argue that they were not given the opportunity to present their case
and submit evidence in support of their rights.
 They also claim that the court did not consider the evidence presented and rendered a
decision without a factual basis.

Rulings:
 The court grants a new trial to allow the respondent National Labor Union, Inc. to
present additional evidence.
 The court believes that the interest of justice would be better served by giving the
movant an opportunity to present relevant evidence and address the main issue
involved.
 Therefore, the court grants the motion for a new trial and remands the case to the
Court of Industrial Relations with instructions to reopen the case, receive all relevant
evidence, and proceed in accordance with the principles of due process and a fair
hearing.
Ratio:
 The court emphasizes that there are cardinal primary rights that must be respected in
administrative proceedings.
 The first of these rights is the right to a hearing, which includes the right to present
one's case and submit evidence.
 The court also states that the decision must be based on substantial evidence, meaning
relevant evidence that a reasonable mind would accept as adequate to support a
conclusion.
 In this case, the court finds that the record is barren and does not provide a factual
basis for a rational conclusion of law, except for the alleged agreement between Ang
Tibay and the National Workers' Brotherhood.
 However, the court grants a new trial to allow the respondent National Labor Union,
Inc. to present additional evidence, including records from the Bureau of Customs and
the Books of Accounts of native dealers in leather.
 The court believes that the interest of justice would be better served by giving the
movant an opportunity to present relevant evidence and address the main issue
involved.
 Therefore, the court grants the motion for a new trial and remands the case to the
Court of Industrial Relations with instructions to reopen the case, receive all relevant
evidence, and proceed in accordance with the principles of due process and a fair
hearing.