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ANG TIBAY vs.

CIR

FACTS:

The respondent National Labor Union, Inc. avers that: (1) Toribio Teodoro, who is the manager
and proprietor of Ang Tibay, was falsely claiming that there is a shortage of leather soles for him
to temporarily lay off the Members of the National Labor Union, Inc. as it was unsupported by
records; (2) the alleged lack of materials was a scheme to discharge systematically the Members
of the NLU, Inc. from work; (3) The National Workers’ Brotherhood of Ang Tibay is an illegal union
which is dominated by Toribio Teodoro; and that (4) The employer, Toribio Teodoro, was guilty of
unfair labor practice for discriminating against the NLU, Inc, and unjustly favoring the National
Workers’ Brotherhood.

The case enumerated the specific powers of the Court of Industrial Relations. The CIR, as the
Court observed is not constrained by technical rules of procedure in hearing the matters before it,
but it does not mean that it can ignore entirely the fundamental and essential requirements of due
process in trials and investigations of an administrative character.

ISSUE:

What are the cardinal rights or the requisites of procedural due process which must be
respected in administrative proceedings?

HELD:

The Court provided the ff. as the requisites of procedural due process in administrative
proceedings:

1. The right to a hearing, which includes the right to present one’s case and submit
evidence in support thereof.
2. Tribunal must consider the evidence presented.
3. Decision must have something to support it.
4. Evidence must be substantial (more than a mere “scintilla”, relevant evidence a
reasonable mind accepts to support a conclusion)
5. Decision must be rendered on the evident presented at the hearing, or at least contained
in the record or disclosed to the parties affected.
6. Tribunal or body or any of its judges must act on its or his own independent consideration
of the law and facts of the controversy and not simply accept the views of a subordinate
in arriving at a decision.
7. The board or body should, in all controversial questions, render its decision in such a
manner that the parties to the proceeding can know the various issues involved, and the
reason for the decision rendered.

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