G.R. No. L-18354; May 30, 1963
CHING BAN YEK CO., INC., petitioner, vs. AUDITOR GENERAL, respondent.

FACTS

Petitioner Ching Ban Yek Co., Inc. sought reconsideration of the Supreme Court’s December 29, 1962 decision. The core legal dispute involved the proper classification, under Republic Act No. 601 (as amended), of hydrogenated cottonseed oil when added to coconut oil in manufacturing vegetable lard. The petitioner argued the decision was contrary to legislative intent, equity, and general welfare, potentially causing hardship to lard manufacturers.
In support of its motion for reconsideration, the petitioner submitted new documentary evidence. This included a sworn certificate from the Senate President, letters and opinions from the Chairman of the National Science Development Board and the Deputy Commissioner of the National Institute of Science and Technology (NIST), and an opinion from an American consultant. The petitioner also requested the admission of photostatic pages from a scientific textbook, “Industrial Oil and Fat Products,” cited in a new NIST memorandum. These documents aimed to refute the technical opinion previously relied upon by the Court.

ISSUE

Whether the newly submitted documentary evidence by the petitioner warrants a reconsideration of the Court’s prior decision which held that hydrogenated cottonseed oil served as a “component” and not a “stabilizer” in vegetable lard manufacture under Republic Act No. 601 .

RULING

The Supreme Court resolved to remand the case to the respondent Auditor General for further proceedings. The Court did not rule on the merits of the motion for reconsideration at this stage. The legal logic for this procedural action was based on the nature of the evidence newly introduced by the petitioner.
The Court noted that the submitted documents constituted new evidence that was not part of the original record. Crucially, the respondent had not been given any opportunity to examine these new documents or to cross-examine the officials and authors responsible for the opinions contained within them. This procedural deficiency was central to the Court’s reasoning. In legal proceedings, especially when new evidence is proffered on motion for reconsideration, fundamental fairness requires that the opposing party be afforded a chance to test the credibility and weight of such evidence.
Therefore, to uphold due process and ensure a complete factual record, the Court deemed it proper to remand the case. This allowed the respondent Auditor General to take appropriate action concerning the new evidence, which could include examination, verification, and potentially a reevaluation of his earlier position in light of the new submissions. The Court’s resolution was thus a procedural safeguard, deferring a substantive ruling until the factual basis could be fully and fairly developed before the administrative body.