Title
Bachrach Motor Co., Inc. vs. Court of Industrial Relations
Case
G.R. No. L-26136
Decision Date
Oct 30, 1978
A labor dispute arose when Bachrach Motor Co. sought to dismiss driver Maximo Jacob after a bus accident. The Court of Industrial Relations dismissed Bachrach's petition due to lack of cross-examination and hearsay evidence, reinstating Jacob with limited backwages.
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Case Digest (G.R. No. L-26136)

Facts:

  1. Background of the Case

    • In 1958, Bachrach Motor Co., Inc. (petitioner) operated the "Rural Transit," a transportation business.
    • The Rural Transit Employees Association (respondent) went on strike, leading to a labor dispute that reached the Court of Industrial Relations (CIR) for compulsory arbitration.
    • The CIR ordered the strikers to return to work and the management to reinstate them under pre-dispute conditions.
  2. Petition to Discharge Maximo Jacob

    • During the pendency of the labor dispute, Bachrach filed a petition on July 24, 1961, seeking authority to discharge driver Maximo Jacob for alleged violations of the Motor Vehicle Law, including an accident on June 9, 1961, which resulted in the destruction of a company bus.
    • The Rural Transit Employees Association countered, claiming the accident was due to a mechanical defect, not Jacob's fault.
  3. Proceedings in the CIR

    • The case was heard on January 23, 1963, with Bachrach presenting Joseph Kaplin as its sole witness and submitting documents (Exhibits "1" to "8-F").
    • Kaplin's cross-examination was postponed multiple times, but he failed to appear as he had left for abroad.
    • On March 8, 1965, the employees' association moved to strike Kaplin's testimony, dismiss Bachrach's petition, and reinstate Jacob with backwages.
  4. CIR's Decision

    • On March 1, 1966, the CIR dismissed Bachrach's petition, lifted Jacob's suspension, and ordered his reinstatement with backwages from the date of suspension.
    • Bachrach's motion for reconsideration was denied, prompting it to file a Petition for Certiorari.

Issue:

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Ruling:

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Ratio:

  1. Right to Cross-Examination

    • The right to cross-examine a witness is a fundamental due process right in both civil and criminal cases. Failure to cross-examine a witness due to the opposing party's fault renders the testimony incomplete and inadmissible.
  2. Hearsay Evidence

    • Documents admitted without supporting testimony are hearsay and cannot be considered competent evidence.
  3. Burden of Proof

    • The burden of justifying an employee's suspension or dismissal lies with the employer. Failure to meet this burden necessitates the employee's reinstatement.
  4. Reasonable Backwages

    • Judicial policy favors limiting backwages to a reasonable period (e.g., three years) to avoid prolonged litigation and ensure fairness.


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