Case Digest (G.R. No. 46496) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the consolidated petitions before the Supreme Court of the Philippines in 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., respondents (G.R. No. 46496, February 27, 1940), the National Labor Union, Inc. (“NLU”) challenged a decision of the Court of Industrial Relations (CIR) which had upheld the non-readmission of eighty-nine of its members following a declared “paro forzoso” (forced stoppage) at the Ang Tibay factory. Toribio Teodoro, manager of Ang Tibay, had alleged a temporary shortage of leather soles and, on September 26, 1938, laid off NLU members. The CIR found that the laborers’ contracts—entered into without a fixed term—terminated upon the forced stoppage and that there was no proof of unfair labor practice or union discrimination. The Solicitor-General moved for reconsideration of certain legal conclusions of the majority opinion, Case Digest (G.R. No. 46496) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedent Facts
- Ang Tibay is a manufacturing enterprise represented by Toribio Teodoro as manager and proprietor. It maintained a company union, the National Workers’ Brotherhood.
- The National Labor Union, Inc. (NLU) organized 89 employees of Ang Tibay, alleging discriminatory lay-off by reason of union affiliation.
- Procedural Background
- The Court of Industrial Relations (CIR), acting on petition by the Secretary of Labor and the parties, heard evidence on whether the exclusion of the 89 workers constituted an unfair labor practice under Commonwealth Act No. 103.
- CIR rendered judgment denying relief for lack of substantial evidence linking the lay-off to union affiliation. Subsequently:
- The Solicitor-General, for CIR, moved for reconsideration of three legal conclusions of this Court’s majority opinion regarding termination of employment by forced stoppage.
- NLU filed a motion for a new trial, alleging newly discovered evidence—records from the Bureau of Customs and local leather dealers—demonstrating a spurious material shortage scheme to oust union members. Ang Tibay opposed both motions.
Issues:
- Solicitor-General’s Motion for Reconsideration
- Whether this Court should revisit its legal conclusions on contracts of indefinite duration and forced stoppage under Commonwealth Act No. 213.
- Whether resolution of the Solicitor-General’s motion is necessary in light of other pending motions.
- NLU’s Motion for New Trial
- Whether NLU’s allegations of spurious shortage of leather soles and an illegal company union present newly discoverable, material evidence.
- Whether the interests of justice require reopening the CIR proceedings to receive such evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)