Case Summary (G.R. No. 46496)
Nature and Powers of the Court of Industrial Relations
The Court of Industrial Relations is a special quasi-administrative tribunal with nationwide jurisdiction to prevent, arbitrate, decide, and settle industrial or agricultural disputes affecting more than thirty workers. Under Commonwealth Act No. 103, it may:
• Invoke voluntary arbitration, mediation, or conciliation.
• Conduct official investigations and compulsory arbitration.
• Fix minimum wages or shares for laborers and maximum rents for tenants when directed by the President.
• Act affirmatively without strict adherence to technical rules of procedure or evidence, yet remain subject to constitutional due process requirements.
Fundamental Due Process Requirements
Although freed from rigid procedural and evidentiary technicalities, the Court must respect core due-process safeguards:
- Right to be heard – Parties must receive a fair opportunity to present their case and evidence.
- Duty to consider evidence – The tribunal must actually weigh and deliberate on evidence presented.
- Support for decisions – Every finding must rest on something in the record; a decision without evidentiary support is void.
- Substantial evidence standard – Conclusions must be supported by evidence a reasonable mind would accept as adequate.
- Decision based on disclosed record – Parties must know and have a chance to meet all evidence upon which a decision relies.
- Independent adjudication – Judges must exercise independent judgment, not merely adopt a subordinate’s recommendations.
- Reasoned opinions – Orders should clearly state the issues decided and the rationale to inform and guide parties.
Evaluation of Evidence and Allegations
On review, the Supreme Court found no substantial evidence that the layoffs were motivated by union affiliation or activity. The record consisted mainly of conflicting counsel statements lacking probative value. Except for the alleged collective agreement between Ang Tibay and the National Workers’ Brotherhood, no factual basis justified the Court of Industrial Relations’ conclusions.
Grant of New Trial and Remand with Instructions
Given the union’s sworn assertion that documentary evidence (customs records, dealers’ account books, and organizational docum
Case Syllabus (G.R. No. 46496)
Parties and Procedural Posture
- Petitioners: Ang Tibay, represented by Toribio Teodoro (manager and proprietor), and the National Workers’ Brotherhood.
- Respondents: The Court of Industrial Relations (CIR) and the National Labor Union, Inc.
- Solicitor-General filed a motion for reconsideration on behalf of the CIR, challenging key legal conclusions of this Court’s majority opinion.
- The National Labor Union, Inc. filed a motion for a new trial (or vacation of judgment and remand to the CIR).
- Ang Tibay filed oppositions to both the motion for reconsideration and the motion for new trial.
- The Supreme Court, after review, declines to pass on the motion for reconsideration and proceeds to address only the motion for a new trial.
Legal Conclusions Challenged in Motion for Reconsideration
- Contracts of employment without fixed duration (individual or collective) terminate:
- By unilateral will of either party;
- At each customary payday;
- Upon completion of the work.
- Workers under non-fixed contracts lose employee status when a forced stoppage (paro forzoso) occurs.
- An employer who refuses readmission of laid-off workers following a forced stoppage is not guilty of unfair labor practice or criminally liable under Commonwealth Act No. 213, article 5, even if motivated by union affiliation, because the contract terminated by operation of the stoppage.
Grounds for Motion for New Trial by National Labor Union, Inc.
- Alleged false claim by Toribio Teodoro of a leather-sole shortage on September 26, 1938, unsupported by Bureau of Customs records or dealers’ books.
- Assertion that the “shortage” was a pretext to discharge all National Labor Union members.
- Toribio Teodoro’s letter to the Philippine Army (September 29, 1938) was a contrivance to avoid bond forfeiture despite contract breach.
- Charge that the National Workers’ Brotherhood is an employer-dominated union controlled by Teodoro, rendering it illegal.
- Emphasis on the necessity of majority rule and elective representation in collective bargaining (Commonwealth Act No. 213, §§ 2 and 5).
- Argument that outdated Civil Code provisions should not govern interpretation of modern American-s