Case Digest (G.R. No. 46496)
Facts:
Ang Tibay, represented by Toribio Teodoro, Manager and Proprietor, and National Workers' Brotherhood, petitioners, vs. The Court of Industrial Relations and National Labor Union, Inc., G.R. No. 46496, February 27, 1940, the Supreme Court En Banc, Laurel, J., writing for the Court.The dispute arose from proceedings before the Court of Industrial Relations (CIR) concerning the alleged exclusion and discharge of eighty-nine laborers from employment at the Ang Tibay establishment. The controversy involved competing unions — the petitioner-associated National Workers' Brotherhood and the National Labor Union, Inc. — and questions whether the employer, represented by Toribio Teodoro, had discriminated against employees because of union affiliation or otherwise committed unfair labor practices.
Following hearings before the CIR, that tribunal rendered an order or award in the controversy (the CIR is the respondent here), which was then brought to this Court. The Supreme Court issued a majority opinion that contained several legal conclusions (quoted by the Solicitor-General and set out in the motion for reconsideration), including propositions about the nature of indefinite employment contracts, the effect of a "paro forzoso" (forced stoppage) on employment relations, and the employer’s liability for refusing to readmit workers after such a stoppage.
After the Supreme Court's majority decision, the Solicitor-General, appearing for the CIR, filed a motion for reconsideration asking the Court to revisit and modify several of those legal conclusions. Separately, the respondent National Labor Union, Inc. filed a motion for a new trial: it alleged (under oath) that key documentary evidence — records of the Bureau of Customs, native leather dealers' books, and other exhibits — was inaccessible to it at the CIR hearing despite due diligence, and that such evidence would prove that the claimed shortage of leather (the employer's stated reason for lay-offs) was a pretext to discharge union members; it also alleged the existence of an employer-dominated company union (the National Workers' Brotherhood) and claimed unfair labor practices by Toribio Teodoro.
The parties submitted opposing memoranda; Ang Tibay filed an opposition to both the Solicitor-General's motion for reconsideration and the National Labor Union's motion for new trial. The Supreme Court re...(Subscriber-Only)
Issues:
- Is it necessary for the Court to pass upon the Solicitor-General's motion for reconsideration of the Court's earlier legal conclusions?
- Should the National Labor Union, Inc.'s motion for a new trial be granted and the case remanded to the Court of Industrial Relations to receive the additional evidence and proceed in accordance wit...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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