G.R. No. 141599 - People vs. Gonzales

The case involves a petition for certiorari filed by the Manila Chauffeurs’ League (the petitioner) against Bachrach Motor Co., Inc. (the respondent).
Prior to the dispute, differences had arisen between the predecessor organization of the League and the corporation regarding the employment and dismissal of chauffeurs.
To resolve these differences, the parties entered into a compromise agreement on August 22, 1938, which was incorporated into the proceedings of the Tribunal of Industrial Relations and accorded the effect of a decision under Article 4 of Commonwealth Act No. 103.

A key provision is found in paragraph XIII, clause 2 of the agreement, which states that:

The company expects the drivers to cooperate with its administration by furnishing enough drivers to operate at least 80% of the registered auto-calesas daily.
The League is obligated to ensure that its members render regular, efficient, and economical service, except under exceptional circumstances such as typhoons or floods.

The agreement did not grant the League an exclusive right to supply drivers for the entire operation but imposed a duty to supply only the number needed to cover the 80% operational requirement.

Almost one year after the agreement, the new president of the Manila Chauffeurs’ League sent a letter to Mary McDonald Bachrach, president of the corporation, proposing that the League should have the instantaneous and exclusive right to furnish all drivers needed for the auto-calesa service.

The letter proposed that the League’s members be exclusively employed until all positions were filled in order to avoid having any member left on the waiting list.

The corporation rejected this proposition, stating that, in accordance with the agreement, it reserved the right to select the best available drivers, whether from the League or from outside sources.

The immediate reinstatement of chauffeurs who had been summarily dismissed or suspended for reasons not expressly approved by the Tribunal in its September 2, 1938 decision;
Exclusive authority for the League’s president to assign or replace drivers for the auto-calesas.

It denied the requested exclusive right for the League to furnish drivers by determining that such an imposition was not the essence of the compromise agreement;
It found that the dismissal of chauffeur Gonzalo Saldana was justified, ruling that his conduct violated the company’s regulations and the terms of the agreement.

The League subsequently sought reconsideration of the October 13 orders through a motion on December 4, 1939, which the Tribunal also denied.
The present petition of certiorari was then filed challenging the Tribunal’s orders.

Whether the Manila Chauffeurs’ League has the right to require that all vacancies and new positions in the auto-calesa service of Bachrach Motor Co., Inc. be filled exclusively with drivers proposed by the League.

The central question is if the League’s claim for an exclusive right in the supply of drivers is supported by the terms of the August 22, 1938, compromise agreement.
A secondary aspect involves the interpretation of the clause outlining the obligation to provide drivers for only 80% of the auto-calesas in operation.

Whether the corporation rightfully expeditiously dismissed chauffeur Gonzalo Saldana.

The issue revolves around whether Saldana’s dismissal was warranted, given that his actions allegedly breached company regulations and the terms of the compromise agreement.
The legality of the dismissal is scrutinized in light of the company’s contractual rights and the precedent on a patron’s prerogative in the employment and discharge of its workers.