Facts:

The case involved Alhambra Industries, Inc. as the petitioner and the Court of Industrial Relations and Alhambra Employees Association (FTUP) as the respondents. The decision was rendered on October 30, 1970. The dispute arose when fifteen drivers and helpers employed by Alhambra Industries were reportedly being denied the rights and benefits accorded to regular employees under collective bargaining agreements. The initiator of this complaint was the acting prosecutor of the Court of Industrial Relations, as it was filed based on claims made by the Alhambra Employees Association. According to the union, these workers were discriminated against solely due to their membership in the union. Petitioner's defense was that these drivers and helpers were independent employees of the salesmen and propagandists, hence they were not entitled to the same benefits afforded to other employees. Despite engaging in negotiations through the grievance machinery provided in the collective bar

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Facts:

Parties Involved

• Alhambra Industries, Inc. (Petitioner)
• Court of Industrial Relations and Alhambra Employees Association (FTUP) (Respondents)

Nature and Background of the Dispute

• The dispute arose from a complaint for unfair labor practice alleging that fifteen drivers and helpers were being denied the privileges, rights, and benefits accorded to other regular employees under the collective bargaining agreement.
• The union claimed that the discriminatory practice was based solely on the drivers’ and helpers’ union membership, as they were classified as separate and independent employees of petitioner's salesmen and propagandists.
• The union had attempted to resolve the issue through the established grievance machinery under the collective bargaining agreement before eventually resorting to filing the complaint.

Collective Bargaining History and Grievance Machinery

• Collective bargaining agreements were signed on March 14, 1962, and February 18, 1964, between the union and petitioner.
• Both parties exhausted the first three steps of the grievance machinery regarding the drivers’ and helpers’ entitlement to benefits.
• Upon failure of resolution through conferences, the union initiated the final step by elevating the issue to the respondent court via an unfair labor practice complaint.

Findings of the Respondent Court

• The court examined the “memorandum of instructions” issued by petitioner and determined that although a salesman or propagandist was nominally responsible for the drivers and helpers, the authority to engage them emanated directly from petitioner.
• It was observed that the drivers and helpers were paid through a “driver allowance” coming from petitioner, which further established petitioner’s control over the employment relationship.
• The instructions dictated by petitioner detailed the duties of the drivers and helpers, including accompanying salesmen, operating company trucks, and assisting with deliveries and inventory preparations.
• Based on these factors, the respondent court found that the fifteen drivers and helpers were, in fact, employees of Alhambra Industries, Inc.

Judgment and Relief Granted

• The respondent court ruled that the drivers and helpers were entitled to all the privileges, rights, and benefits provided to regular employees, retroactive from the March 14, 1962 agreement up to the present.
• The court’s decision included ordering petitioner to extend these benefits and to cease the unfair labor practice.
• A preliminary injunction issued earlier was subsequently lifted and set aside.

Petitioner’s Appeal and Arguments

• Petitioner argued that the drivers and helpers were not its employees but rather independent workers employed by its salesmen and propagandists.
• The appellant contended that the respondent court exceeded its jurisdiction by awarding relief even though no unfair labor practice had actually been committed, relying on a statement that the issue hinged on employee status rather than union discrimination.
• Petitioner maintained that, since the grant of benefits depended on the court’s finding of employee status and not on discriminatory practices based on union affiliation, the decision should have been dismissed in favor of conciliation and mediation.

Issue:

Employee Status Determination

• Whether the fifteen drivers and helpers should be considered employees of Alhambra Industries, Inc.
• Whether the method of employing them indirectly through salesmen and propagandists was a mere artifice to deny them their rightful status.

Application of the Collective Bargaining Agreement

• Whether the petitioner’s refusal to extend the privileges and benefits to the drivers and helpers amounted to an unfair labor practice in violation of the collective bargaining agreement.
• Whether the grievance machinery had been properly exhausted before the matter was elevated to the court.

Jurisdiction and Remedial Measures

• Whether the respondent court acted within its jurisdiction by issuing a remedy based on the finding that an unfair labor practice had been committed.
• Whether the dismissal of the complaint, as advocated by petitioner under section 5(c) of the Industrial Peace Act, was justified.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)