Ang Tibay v. CIR

Summary

Landmark 1940 Supreme Court case establishing fundamental due process requirements for quasi-judicial administrative bodies. Arose from labor dispute where Ang Tibay factory allegedly discriminated against National Labor Union members through pretextual layoffs while favoring company-dominated union. Supreme Court found original Court of Industrial Relations proceedings lacked substantial evidence and proper factual foundation. Court granted new trial and established seven cardinal due process principles that administrative tribunals must observe: right to hearing, duty to consider evidence, requirement of evidentiary support, substantial evidence standard, decisions based on disclosed evidence, independent judicial consideration, and clear reasoning. Case significantly shaped administrative law by requiring quasi-judicial bodies to follow essential procedural safeguards while maintaining flexibility from rigid technical rules.