THIRD DIVISION

(Supplemental)




PARTIES TO DISPUTE:

BROTHERHOOD OF RAILWAY AND STEAMSHIP CLERKS, FREIGHT HANDLERS, EXPRESS AND STATION EMPLOYES




STATEMENT OF CLAIM: Claim of the System Committee of the Brotherhood (GIr5643) that:




EMPLOYES' STATEMENT OF FACTS: There is in evidence an Agreement bearing effective date October 1, 1940, reprinted May 2, 1955, including revisions, (hereinafter referred to as the Agreement) between the Southern Pacific Company (Pacific Lines) (hereinafter referred to as the Carrier) and its employer represented by the Brotherhood of Railway and Steamship Clerks, Freight Handlers, Express and Station Employes (hereinafter referred to as the Employes) which Agreement is on file with this Board and by reference thereto is hereby made a part of this dispute.


Position No. 16 Cashier was vacant September 20, 1961 through October 8, 19611, account vacationing incumbent. Absent of a qualified unassigned employe, W. G. Cadden, incumbent of Relief Position No. 1, was placed thereon under the provisions of Rule 34 of the Agreement.



OPINION OF BOARD: iThe facts giving rise to this dispute are not in question. A short vacancy (less than 30 days) occurred on Relief Position No. 1 between September 20 and October 8, 1961, which included two days per week (round house clerk), two days per week (cashier), and one day per week (clerk-baggageman). The controversy arises from the filling of the clerk-baggageman position to which there was no regularly assigned employe.


Carrier filled that position with an unassigned employe who had not worked 40 hours during that week.


Petitioner contends that Carrier should have filled the position with a regular assigned employe, and alleges violation of Rule 34 (c) of the Agreement and an "understanding" dated June 12, 1957 between the Employes' Negotiating Committee and Carrier's Assistant Manager of Personnel.










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The claim of violation of Rule 34 (c) is unwarranted. There was no, "written application" made by the Claimant as is required, and we need not consider it further.




Petitioner contends that on June 12, 1957 the parties entered into an agreement that an unassigned employe must be qualified for all positions included in a relief position before he can be assigned.


Parenthetically it should be noted that neither the employe assigned to the position nor the Claimant were qualified in this respect. The Carrier states that "neither the Claimant nor the unassigned employe involved were qualified for any position included in the relief position with exception to the one day fill out position in the schedule of Clerk-Baggageman, for which position the unassigned employe who had performed less than 40 hours of work in his workweek was eligible and used thereon on date involved as provided in Rule 34 (b)."


On the property, Petitioner alleged violation of the June 12, 1957 agreement styled "Memorandum of Understanding", and, alternately, "Memorandum of Agreement".






Elsewhere in the same letter:



Petitioner admits that such an "understanding", in written form, did not exist. Petitioner admits that it was an oral understanding which was never reduced to writing.


Even if there was in fact an oral understanding and it was raised in such a manner on the property as to give Carrier full notice, the record's paucity of competent and probative evidence substantiating such an alleged agreement precludes us from inquiring further into its substantive effect.


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FINDINGS: The Third Divisiom of the Adjustment Board, upon the whole record and all .the evidence, finds and holds:




That the Carrier and the Employes involved in this dispute are respectively Carrier and Employes within the meaning of the Railway Labor Act, as approved June 21, 1934;


That this Division of the Adjustment Board has jurisdiction over the dispute involved herein; and












Dated at Chicago, Illinois, this 31st day of March 1966.

LABOR MEMBER'S DISSENT TO AWARD 14290,

DOCKET CL-15281


I dissent to Award 14290, Docket CL-1528,1, because I cannot agree that there was any "paucity of competent and probative evidence substantiating" the agreed and accepted interpretation requiring that unassigned employes be qualified for all positions included in a relief assignment, which was what was here involved.


The oral understanding was buttressed by Carrier officers instructions of record which read in part:



Another read in part:



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And in another it reads in part:



Carrier's basis for initially declining this claim was that neither Claimant nor the extra employe were qualified to fill all positions included in the relief assignment. The Superintendent stated:



The highest officer held that:


Thus the only thing which the Award points out is the value of reducing such understandings to writing so that neither party can later deny them.

As stated earlier, I felt there was sufficient evidence to support the existence of the understanding. There is also evidence that that interpretation was rejected by Carrier in this case because neither Claimant nor the extra clerk were qualified for all positions included in the relief assignment.





                      4-20-66


14290

CARRIER MEMBERS' ANSWER TO LABOR MEMBER'S DISSENT,

AWARD 14290, DOCKET CL-16281 (Referee Zumas)


It is elementary that Claimant has the burden of proving all essential elements of the claim. See Awards 13028 (Hall), 12256 (Dolnick), 10946 (Dorsey), 10048 (Dugan), among many others.


As stated in Award 10950 (Ray): "The burden is not on the Carrier to show that its action is authorized by some provision in the Agreement. Rather the burden is on the complaining Employes to show that the action violates some portion of the Agreement."


In this case the Claimant charges Carrier with violation of an alleged oral understanding which expressly disqualified unassigned employes from filling temporary vacancies in relief assignments under the circumstances here involved, and that is the only violation charged. The most essential element of the claim is obviously the alleged oral understanding, the existence of which is denied by Carrier.


The Employes failed to prove that the alleged oral understanding exists: their evidence is both inadmissible and demonstrably erroneous.


In all handling on the property, the Employes contended that there was a written agreement. However, in final conference they were convinced that no such written agreement existed. (This inexcusable confusion of the Employes may have been the result of a change in the office of General Chairman between the date of the alleged agreement and .the date of this claim.)


Having been convinced in final conference on the property that they had no written agreement, the Employes took a new approach in their submission to this Board and claimed an "oral understanding." To prove their alleged oral understanding they submitted two types of evidence.


First, they submitted what purports to be an unsigned written report by a "negotiating committee." This alleged report to the Employes would be of no value if it were admissible, for it is purely self-serving, it does not bear any signature or other authentication, and it does not allege that any agreement or understanding was reached. It simply states that an opinion was requested and received from a Carrier officer during an informal discussion. In any event, we are precluded from considering this as evidence in this case because the record shows that it was never submitted to Carrier during handling of the claim on the property.


The other evidence submitted by the Employes purports to be copies: of letters allegedly written by three of Carrier's ten Division Superintendents. These letters are also irrelevant. None of them makes any reference to the alleged understanding, and one of them is dated ten months prior to the date of the alleged understanding. These letters are also inadmissible, for they, too, were not submitted to Carrier or referred to in the handling of this claim on the property.


As a general rule, this Board will not consider such evidence when it has not been submitted to the other side during handling on the property. Awards 9029, 10529, 11174, 12012, among many others.


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(1 'he Employes place greatest emphasis on the alleged letter of the Super
intendent on the Shasta Division (the Division where the claim arose) and
the dissenter quotes from this letter first. This letter is demonstrably false.
The alleged author thereof was not a Superintendent of any division, much
,less the Shasta Division. He was only a trainmaster. He was, therefore, in
no position to make an interpretation of the Clerks' Agreement, even on a
local basis. Furthermore, he has no record of ever having written such a
letter as that asserted by the Employes. The obviously demonstrable error
of this alleged evidence of the Employes clearly demonstrates the wisdom in
the rules that prohibit presentation to the Board of evidence which has not
been presented to the other side and fully discussed on the property.

The Employes submit nothing else as evidence. They do resort to inneundos, alleging there have been certain payments of such claims to which 'they are forbidden by agreement from referring. If this allegation is true, 'the Employee have clearly committed a breach of confidence by violating their pledge to Carrier in making compromise settlements. However, we must 'assume the allegation itself is false, for it was never during handling on the property and Carrier emphatically denies that there is any truth in it.


I The record is thus completely barren of any admissible proof that the parties ever made the disputed oral understanding on which the claim is expressly based. In these circumstances, the Board had no alternative but to deny the claim, irrespective of its views concerning the validity of an understanding. See Awards 2140 (Thaxter), 5057 (Kelliher), 10442 (Gray) and 13154 (McGovern) on the treatment this Board has accorded such oral understandings.

                        /s/ G. L. Naylor

                        /s/ R. A. DeRossett

                        /s/ C. H. Manoogian

                        /s,/ W. M. Roberts


Keenan Printing Go., Chicago, Ill. Printed in U. S. A.
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