Case Digest (G.R. No. L-25883)
Facts:
Caltex (Philippines) Inc. v. Caltex Dealers Association of the Philippines, Inc., G.R. No. L-25883, April 29, 1969, the Supreme Court En Banc, Dizon, J., writing for the Court.The petitioner is Caltex (Philippines) Inc. and the respondent is Caltex Dealers Association of the Philippines, Inc., a duly organized and registered labor union composed of operators of company-owned Caltex service outlets. The Association filed Case No. 3970-ULP before the Court of Industrial Relations (CIR) alleging unfair labor practice in that petitioner refused to meet, confer and bargain with the Association.
Petitioner resisted on the ground that there was no employer-employee relationship because the dealers were independent entrepreneurs or independent contractors. During the CIR proceedings, upon motion of the Association the CIR issued a subpoena duces tecum requiring production of documents known as "DAPLs" (District Authorized Price Letters); petitioner produced DAPLs at that time.
At a subsequent hearing (November 29, 1965) the Association moved the CIR for another subpoena duces tecum commanding production of DAPLs for specific dealers (Tian Pian, Tan Bong Tiong, Antonio Nocum, Josefa Tan, Pedro Interior and Torquato Carlos) covering years 1964–1965. Petitioner objected and, on December 4, 1965, moved to quash the subpoena on grounds that the documents sought were immaterial or merely cumulative, that the subpoena was unreasonable and oppressive because of the volume of documents, and that the Association was merely "fishing for evidence."
The CIR denied the motion to quash in an order dated January 6, 1966. Petitioner’s motion for reconsideration was likewise denied by the CIR en banc on March 12, 1966. Petitioner filed a notice of appeal with the CIR and then filed the present petition for certiorari with the Supreme Court on March 30, 1966 seeking reversal of the CIR’s order and resolution denying the motion to q...(Subscriber-Only)
Issues:
- Did the Court of Industrial Relations commit grave abuse of discretion in denying petitioner’s motion to quash the subpoena duces tecum?
- Were the documents sought by the subpoena duces tecum immaterial, merely cumulative, oppressive in volume, or the product of improper "fishing for evidence" so...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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