G.R. No. L-25883 April 29, 1969
CALTEX (PHIL.) INC., petitioner, vs. CALTEX DEALERS ASSOCIATION OF THE PHILIPPINES, INC., and the COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

The respondent Caltex Dealers Association of the Philippines, Inc. is a labor union composed of operators of company-owned outlets selling petitioner Caltex (Philippines) Inc.’s petroleum products. The Association filed an unfair labor practice case (No. 3970-ULP) with the Court of Industrial Relations (CIR) against Caltex, alleging refusal to bargain collectively. Caltex’s defense was the absence of an employer-employee relationship, claiming the dealers were independent entrepreneurs or contractors. During the hearing, the CIR, upon the Association’s motion, issued a subpoena duces tecum compelling Caltex to produce “District Authorized Price Letters” (DAPLs). Subsequently, the CIR issued another subpoena duces tecum for similar DAPL documents covering specific dealers for the years 1964 and 1965. Caltex moved to quash this second subpoena, arguing the documents were immaterial, merely cumulative, that the subpoena was unreasonable and oppressive, and that its purpose was merely to “fish for evidence.” The trial court denied the motion to quash, and the CIR en banc denied Caltex’s motion for reconsideration. Caltex then filed the present petition for certiorari.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion in issuing the second subpoena duces tecum, requiring Caltex to produce the specified DAPL documents.

RULING

The Supreme Court denied the petition and affirmed the CIR’s order and resolution. The Court held that the CIR did not commit grave abuse of discretion. It ruled that: (1) The documents sought were material to the case, as they were intended to prove the extent of control and supervision Caltex exercised over the Association’s members in a specific area, which was central to determining the existence of an employer-employee relationship. Since Caltex had previously produced similar documents without claiming immateriality, it was estopped from raising that issue. (2) The documents were not merely cumulative, as the first set covered stations in one supervisory area, while the second set covered a different area, and the control exercised might differ. (3) The subpoena was not unreasonable or oppressive, as the Association alleged the documents were definite, particularized, and fewer in number than those previously produced. (4) The purpose of “fishing for evidence” is not prohibited; it is allowed under the Rules of Court on discovery to adequately prepare for trial and simplify issues, and such practice is even more permissible in the CIR, whose proceedings are not strictly governed by ordinary procedural rules.