Landrón v. Puerto Rico Labor Relations Board

87 P.R. 87
CourtSupreme Court of Puerto Rico
DecidedJanuary 21, 1963
DocketNo. 69
StatusPublished

This text of 87 P.R. 87 (Landrón v. Puerto Rico Labor Relations Board) is published on Counsel Stack Legal Research, covering Supreme Court of Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Landrón v. Puerto Rico Labor Relations Board, 87 P.R. 87 (prsupreme 1963).

Opinion

Mr. Justice Blanco Lugo

delivered the opinion of the Court.

The Puerto Rico Labor Relations Board filed two complaints against the San Juan Racing Association, Inc. charging it with laying off, for union activities, racing agents Héctor Landrón, Salvador Colls, and Felipe Ayala, and, hence, with committing unfair labor practices within the meaning of subds. (a)1 and (c)2 of § 8 of the Puerto Rico Labor Relations Act (No. 130 of May 8, 1945, 29 L.P.R.A. § 69(a) and (c) ). The respondent moved for dismissal of both complaints on the following grounds: (1) it challenged the jurisdiction of the State Board to take cognizance of the case; and (2) it alleged as a special defense that racing agents are not employees within the meaning of § 2 of the Act. The second question was sustained and, consequently, both complaints were dismissed. To review this ruling the corresponding-petition for review was filed.

In the decision and order issued by the Board the existing relationship between respondent and the racing agents is described as follows:

“. . . For the purpose of increasing the total of the bets, respondent designates agents throughout the Island of Puerto Rico. The agents provide and pay the rental for the premises where it is installed. They pay light, water, telephone, and promotion expenses. They designate assistants, if deemed necessary, for whose services the agent pays and is responsible for their negligence. Respondent does not intervene in the designation of the assistant, in the salary nor in any other condition of his em[89]*89ployment. [The agents] provide all equipment and material necessary for the operation of the agency, with the exception of a punching machine and the cuadros and papeletas which are supplied by respondent. However, they must pay for the spoiled cuadros and papeletas and a rental of $10 monthly for every additional punching machine needed for the operation of the business. Although respondent has fixed the minimum hours during which the agency shall be open to the public, the agents may determine the maximum number of hours devoted to their agency. They may delegate, and actually delegate, the operation of the agency to their assistants or relatives. They may engage, and actually engage, in other noncompetitive business activities. They do not receive a fixed salary nor appear in respondent’s payroll, nor is any deduction made to them for income tax, social security, and unemployment insurance. They receive as compensation 10 per cent of the total amount wagered plus four cents for every cuadro and three cents for every pa-peleta. This compensation is established by the Regulations of the Racing Commission of Puerto Rico. Their gains depend on the individual effort of each agent.”

From the report of the trial examiner who presided the hearing and from the decision of the Board there appear other facts which it is necessary to consider jointly with those already recited in order to arrive at the determination of the crucial test involved in this appeal, the true status of racing-agents in connection with the enterprise. It is well to point out that the San Juan Racing Association, Inc. has designated an agency inspector to verify whether the agencies meet the necessary requirements as to physical facilities, even though the evidence showed that the inspections are not frequent. The enterprise periodically remits instructions to the agents on the preparation, repair, and renewal of the premises where the agency 3 is established and on the preparation and delivery [90]*90of the material bet.4 Meetings were held to acquaint the agents with the functioning and coordination of the work. Among the agents are persons who are absent, professionals, public employees, and charity associations.

[91]*91 The definition of the term “employee” contained in § 2 of the Act, 29 L.P.R.A. § 63,5 is worded in the broadest terms possible, and only admits as express exceptions that of individuals employed in the domestic service or in the service of their parents, spouse, and the executives and supervisors. We therefore see that, unlike the situation under the federal legislation since the enactment in 1947 of the Taft-Hartley Act (§2(3), 29 U.S.C. § 152(3)), our statute does not expressly exclude independent contractors.6 The amendments incorporated on that date were not limited to establishing the exclusion of independent contractors from the category of employees, but according to the legislative history of the measure 7 the National Board is instructed to apply the ordinary tests of the common law of agency in determining the status of the employee covered by its provisions or of independent contractor. Until then the courts as well as the Board had departed from the common-law rules in making such determination and rather rested on the broad purpose of the Act to protect and promote collective bargaining. Thus, National Labor Relations Board v. Hearst Publications, Inc., 322 U.S. 111 (1943), announces the criterion [92]*92that in order to decide whether or not a person is an employee within the coverage of the statute, the determination of his economic condition in relation to another carries weight, so that the purposes underlying the statute call for his protection; in other words, the economic facts may outweigh the traditional legal distinctions of the common law.8 See note in 17 Geo. Wash. L. Rev. 404 (1949).

The common-law test applied is that of “control retention.” In Kansas City Star Co., 76 N.L.R.B. 384 (1948), first case on independent contractor decided by the National Board after the 1947 amendments, that agency laid down the rules to be followed in accomplishing the congressional purpose, and as to independent contractors it said, citing from the report of the Labor Committee of the Housd of Representatives of the United States on the bill which became the Taft-Hartley Act supra, that it comprised those persons (1) who undertake to do a job for a sum certain; (2) decide how the work will be done; (3) usually hire others to do the job; and (4) depend for their income, not upon wages, but upon what they may receive. See National Van Lines, Inc. v. N.L.R.B., 273 F.2d 402 (C.A. 7, 1960) ; Los Angeles Evening Herald and Express, 102 N.L.R.B. 103 (1953) ; National [93]*93Labor Relations Board v. Steinberg, 182 F.2d 850 (C.A. 5, 1950), points out that the employer-employee relationship exists only where the employer has the right to control and direct the work, not only as to the final result, but also as to the manner and means by which the result is accomplished. See, also, United Insurance Company of America v. N.L.R.B., 304 F.2d 86 (C.A. 7, 1962) ; A. S. Abell Co., 137 N.L.R.B., No.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
87 P.R. 87, Counsel Stack Legal Research, https://law.counselstack.com/opinion/landron-v-puerto-rico-labor-relations-board-prsupreme-1963.