Manila Chauffeurs' League v. Bachrach Motor Co.
REITERATIONFacts
The Antecedents: Differences arose between the Manila Chauffeurs' League (League) and Bachrach Motor Co., Inc. (Company). The parties entered into a convenio (agreement) on August 22, 1938, which was submitted to and approved by the Court of Industrial Relations, having the effect of a decision. Procedural History: The League filed a petition for certiorari against two orders of the Court of Industrial Relations dated October 13, 1939, and a subsequent order dated December 4, 1939, denying a motion for reconsideration. The first order denied the League's request for exclusive right to furnish drivers for the Company's auto-calesas and upheld the dismissal of Gonzalo Saldaña. The second order denied the motion for reconsideration. The Petition: The League sought to compel the Company to exclusively hire drivers from its membership and to reinstate Gonzalo Saldaña. The League also argued that its members were industrial partners and thus subject to Article 138 of the Code of Commerce.
Issue(s)
Whether the Manila Chauffeurs' League has the right to demand that all vacancies and new positions in the Company's auto-calesa service be filled by drivers proposed by the League. Whether the Company has the right to dismiss the driver Gonzalo Saldaña from its service.
Ruling
The Supreme Court affirmed the orders of the Court of Industrial Relations, denying the petition for certiorari.
Ratio Decidendi
On the right to furnish drivers: The Court held that the collective bargaining agreement of August 22, 1938, did not grant the League the exclusive right to supply all drivers. Clause 2 of paragraph XIII of the agreement merely stipulated that the League would cooperate with the Company's administration by furnishing drivers for at least eighty percent (80%) of the registered auto-calesas in operation daily. This clause imposed an obligation on the League, not an exclusive right to supply drivers. The Court reasoned that since the Company invested capital, owned the auto-calesas, and bore responsibilities for damages arising from their operation, it logically and justly retained the exclusive right to freely choose the drivers for its service without imposition from the League. The Court cited the principle that the law does not interfere with the employer's normal exercise of the right to choose and dismiss employees, as established in the case of Pampanga Bus Co., Inc. v. Pambusco Employees' Union, Inc.. On the dismissal of Gonzalo Saldaña: The Court found that Gonzalo Saldaña was dismissed for just cause. The evidence showed that on August 13, 1939, auto-calesa No. 856, assigned to Saldaña, was operated by another driver, S. Villaruel, without the Company's knowledge or consent. Later that day, the same auto-calesa was found being driven by Alfredo Amorosa, also without the Company's consent. This conduct was strictly prohibited by company regulations and constituted a sufficient cause for summary dismissal under paragraph IX of the August 22, 1938, agreement. The Court rejected the League's argument that Article 138 of the Code of Commerce applied, stating that this provision concerns an industrial partner engaging in business without permission, whereas Saldaña's case involved a violation of specific company regulations and the collective bargaining agreement.
Main Doctrine
The employer retains the exclusive right to choose its employees, and this right is not infringed by a collective bargaining agreement that obligates the labor union to furnish drivers, but does not grant the union the exclusive right to supply all drivers. Furthermore, a violation of company regulations constituting a sufficient cause for summary dismissal, as stipulated in the collective bargaining agreement, justifies the termination of an employee.