HomeMy WebLinkAbout2014-4119.Phagau.16-01-22 DecisionCrown Employees
Grievance Settlement
Board
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Toronto, Ontario M5G 1Z8
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Commission de
règlement des griefs
des employés de la
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Toronto (Ontario) M5G 1Z8
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GSB#2014-4119
UNION#2014-0378-0082
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Phagau) Union
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The Crown in Right of Ontario
(Liquor Control Board of Ontario) Employer
BEFORE Daniel Harris Vice-Chair
FOR THE UNION Ed Holmes
Ryder Wright Blair & Holmes LLP
Counsel
FOR THE EMPLOYER Adrienne Couto
Liquor Control Board of Ontario
Counsel
HEARING September 21, October 8, 2015
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Decision
The Proceedings
[1] In this matter the union grieves on behalf of Samuel Phagau, hereafter “the
grievor”, that his discharge was unjust. This decision deals with a union motion
for an order restricting the employer from calling certain evidence. The grievor
was discharged for a number of alleged infractions while he was working in
"tunnel car number eight" and for his manner of driving his personal vehicle in the
employee parking lot.
[2] A tunnel car is essentially a high level vehicle from which the operator picks
orders for delivery from the Durham Warehouse to the retail stores. Each tunnel
car is equipped with a video camera which records activity in the cab of the
vehicle. As a result of a complaint from a fellow employee who used the car in a
shift following the grievor's shift, management viewed the video tape and
determined that the grievor had been guilty of a number of employment
infractions including picking orders while not tied-off, placing his feet outside of
the cab onto the conveyor belt, using his electronic device while in the tunnel
vehicle and urinating in the cab.
[3] After two managers viewed the videotape it inadvertently was not saved. In this
motion, the union seeks a ruling that evidence from the managers of what they
saw on the tape is inadmissible.
The Factual Context
[4] The facts germane to this application are not in dispute. The employer intends to
call two witnesses with respect to what they saw on the videotape.
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[5] The union requested access to the videotape as part of the grievance process.
That request was denied on the basis that the grievor would simply tailor his
evidence to what he saw on the tape.
[6] As set out above, the tape was not saved. The employer has systems in place in
the warehouses and stores that make a video record. It is a centralized system
whereby the images are retained for 14 days and then erased. Unless a request
is made to retain portions of the videotape it is automatically erased. Here, the
request to retain the tape was made in a timely fashion. Regrettably, a technical,
programming error, made during the camera setup by the installation team,
overwhelmed the storage capacity of the system causing all video prior to
November 7, 2014 to be overwritten if it had not been saved. Accordingly, the
managers viewed the video and requested that it be retained, but the images
were lost because of this technical failure.
[7] The union accepts that it was inadvertence that resulted in the videotape not
being retained.
The Submissions of the Parties
[8] In making their submissions, the parties relied on the following authorities. I have
read and considered these decisions and they inform the award that follows.
[9] The union relied upon the following authorities: Ontario Public Service
Employees’ Union (Larman) v. Ontario (Ministry of Community, Family and
Children Services, 2006 CarswellOnt 3832 (Ontario Court of Appeal); Labour
Relations Act, 1995, S.O. 1995, c.1, Sched.A, s.48 (12); Canadian Labour
Arbitration (Brown and Beatty, Canada Law Book, 3:4310; O.P.S.E.U v. Ontario
(Ministry of Community Safety & Correctional Services (Lavalee), 2011
CarswellOnt 10295 (Watters); R v. Khan, [1990] 2 S.C.R. 531 (S.C.C.);
O.P.S.E.U (Iyamu). v. Ontario (Ministry of Children and Youth Services
(Unreported, September 17,2015, Nairn, GSB #2013-3490 et al); R v. Khelawon,
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[2006] 2 S.C.R. 787 (S.C.C.); O.P.S.E.U. (Marshall et al, Preliminary Award) v.
Ontario (Ministry of Community Safety and Correctional Services), (2013), 232
L.A.C. (4th) 181 (Abramsky); O.P.S.E.U. (Marshall et al ) v. Ontario (Ministry of
Community Safety and Correctional Services (Unreported, September 16, 2013,
Abramsky, GSB # 2012-1308 et al.); British Columbia Institute of Technology v.
B.C.G.E.U. (1995), 47 L.A.C. (4th) 99, (Blasina); O.P.S.E.U. (Gillis et al) v.
Ontario (Ministry of Community Safety and Correctional Services) (2005) 145
L.A.C. (4th) 205 (Abramsky); Calgary Co-operative Assn. and UCCE (2015), 253
L.A.C. (4th) 403 (McFetridge).
[10] The employer relied upon the following authorities: Labour Relations Act, 1995,
S.O. 1995, c.1, Sched.A, s.48 (12); Re Greater Niagara Transit Commission and
Amalgamated Transit Union, Local 1582 (1987), 61 O.R. (2d) 565 (Ont. Div. Ct.);
Kimberly-Clarke Inc. & Industrial Wood and Allied Workers of Canada, Local 1-
92-4 (Meo Grievance), [1996] O.L.A.A. No. 46 (Bendel); R. v. Swartz, [1977] O.J.
No. 694 (Ont. C.A.), aff’d [1979] 2 S.C.R. 256; R. v. Newfoundland and Labrador
Assn. of Public and Private Employees, [2007] N.J. No. 329 (Nfld. Supreme Ct
Trial Div.); Rite Pak Produce Co. v. Teamsters, Local 419 (Costa Grievance),
[2012] O.L.A.A. No. 211 (Davie); R v. After Dark Enterprises Ltd., [1994] A.J. No.
1057 (Alb. C.A.), rev’g [1993] A.J. No. 411 (Alb. Q.B.); R v. Pires, [2012] O.J. No.
5421 (Ont. C.J.); R v. Lapensee, [2014] O.J. No. 1753 (Ont. S.C.J.); Brampton
(City) v. Lam, [2015] O.J. No. 4140 (Ont C.J.); Ontario Public Service Employees
Union v. Ontario (Ministry of Community Safety and Correctional Services (Gillis
Grievance) (2005), 145 L.A.C. (4th) 205 (Abramsky) (Ont. G.S.B.); Ontario Public
Service Employees Union v. Ontario (Ministry of Community Safety and
Correctional Services) (Ewing Grievance), [2011] O.G.S.B.A. No. 179 (Briggs)
(Ont. G.S.B.); 1293446 Ontario and U.F.C.W., Loc. 206 (Cruz) (Re) (2004), 127
L.A.C. (4th) 436 (Trachuk); R. v. Brennan Paving and Construction Ltd., [1998]
O.J. No. 4855 (Ont. C.A.); R v. Johnson, [2007] O.J. No. 2228 (Ont. C.A.); R v.
La, [1997] 2 S.C.R. 680 (S.C.C.); R. v. Bero, [2000] O.J. No. 4199 (Ont. C.A.); R
v. Scott, [2002] O.J. No. 1937 (Ont. C.A.); R. v. G.S., [2010] O.J. No. 1666 (Ont.
C.A.); R. v. Bradford, [2001] O.J. No. 107 (Ont. C.A.); Canada Post Corp v.
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C.U.P.W., [1992] B.C.J. No. 333 (B.C. S.C.); Universite du Quebec a Trois-
Rivieres v. Larocque, [1993] 1 S.C.R. 471 (S.C.C.); Greater Toronto Airports
Authority v. Public Service Alliance of Canada (Buehler Grievance) (2007), 158
L.A.C. (4th) 97 (Bendel); Hotel-Dieu Grace Hospital v. Ontario (Nurses’ Assn.)
(Jacobs Grievance) (2010), 195 L.A.C. (4th) 383 (Crljenica); Emerge Tube v.
Unifor, Local 523 (Adamo Grievance) (2013), 238 L.A.C. (4th) 431 (Bendel);
Ontario Public Service Employees Union v. Ontario (Ministry of Community,
Family and Children’s Services (Larman Grievance), [2003] O.G.S.B.A. No. 48
(Abramsky) (Ont. G.S.B.), aff’d [2005] O.J. No. 221 (Ont. S.C.J.), rev’d 81 O.R.
(3d) 419 (Ont. C.A.), leave to appeal refused [2006] S.C.C.A. No. 367 (S.C.C.),
OPSEU (Hall) and Ontario (Liquor Control Board of Ontario) GSB No. 2012-0551
et al (2013), 231 L.A.C. (4th) 90.
[11] The union submitted that the video recording is the best evidence, and if the
video recording is not available, then anything flowing from it should be excluded.
It said that such an outcome would be consistent with OPSEU (Larman), supra.
In that matter, the employer had engaged a third-party consultant to conduct a
workplace review. The consultant interviewed numerous employees and
concluded that the grievor should be transferred to another office in view of the
history of conflict in his home office. The union grieved, and at the grievance
arbitration hearing it became apparent that the third-party consultant had
destroyed the materials relied upon in making its recommendations. On a
preliminary application, the Vice-Chair of the Board "concluded that without the
lost evidence, both the union's ability to advance its case and the employer's
ability to defend its actions were "irreparably prejudiced". Without hearing the
employer's evidence on the merits of the grievance, the arbitrator ruled that the
appropriate remedy was to allow the union's grievance." (Paragraph 1, Larman,
supra).
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[12] The Ontario Court of Appeal concluded that there had been a denial of natural
justice. Here the union relies upon paragraph 27 of that decision, which reads as
follows:
27. Inadvertent destruction of evidence can be remedied in a
variety of ways. An adverse inference can be drawn against the party
who bears the obligation to produce the document or evidence in
question: Coriale (Litigation Guardian of) [ v. Sisters of St. Joseph of
Sault Ste Marie (1998) 41 O.R. (3d) 347]. Similarly, the party failing to
produce relevant material may be precluded from relying on that or
related documents or evidence: [Werner v. Warner Auto-Marine Inc.
(1996), 3 C.P.C. (4th) 110 (Ont. C.A.)]. No case was cited to us for the
proposition that a claim or grievance can be allowed, without hearing
all the evidence that is available, on the ground of the responding
party inadvertently failed to produce relevant documents or evidence.
[13] The union submitted, in essence, that the Court of Appeal laid out three
procedural options to deal with the destruction of documents. The first is to draw
an adverse inference against the party who bears the obligation to produce the
document. The second is to preclude the calling of the evidence being relied
upon, and, the third is to preclude any other related documents or evidence.
Here, the union relies upon the third option, which is to preclude anything flowing
from the missing, direct evidence, that being the evidence of the managers who
viewed the tape.
[14] In the alternative, the union submitted that the evidence of the managers would
be hearsay. As hearsay, it said that the arbitral jurisprudence accepts that it could
not be the sole basis of a critical finding of fact. If there is no corroboration of the
hearsay, the evidence of the managers could be given no weight. Because this is
a discharge case, the employer's evidence must be clear, cogent and convincing,
which it says is consistent with the Board’s jurisprudence. Such hearsay would
fail that test. The union said that hearsay is presumptively inadmissible subject to
my jurisdiction under the Ontario Labor Relations Act, 1995, s. 48 (12) (f). It
submitted that, given the absence of the best or direct evidence, the managers’
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evidence could be given no weight, and there is no reason to take up hearing
time with the calling of such valueless evidence.
[15] The union also reviewed the test for the admission of hearsay evidence set out in
R. v. Khan, that being necessity and reliability, and the cases that followed it. It
noted that the Khan case was a criminal matter dealing with the admissibility of
hearsay evidence relating to the utterances of a child in the context of charges
against the accused of sexual misconduct directed toward the child. On that
basis, the union submitted that Khan has limited applicability generally, and is not
applicable here.
[16] The union also submitted that it will contest the employer's account of the facts. It
said that the jurisprudence supports the exclusion of the managers’ evidence
relating to the videotape on the basis that the inquiry before me does not deal
with what the employer relied upon in discharging the grievor but whether or not
the employer has sufficient evidence to establish just cause. It said it would be
unfairly hobbled by the inability to cross-examine the managers on the basis of
what the tape shows, not having seen the tape itself nor having it available as
part of the record. It said that there are going to be factual disputes, and the
videotape would show exactly what the grievor was doing. The trustworthiness of
the managers’ evidence would be questionable and will detract from the Board’s
fact-finding on critical facts.
[17] The union also relied on Calgary Co-operative Association (Komicha), supra, as
a case most closely aligned factually to the matter before me. In that matter the
grievor, a gas station attendant, had kept tips from customers, contrary to the
employer's policy. This was recorded on videotape, which was shown to the
union as part of the grievance procedure. At the hearing, the employer produced
a single still frame from the videotape, as the videotape itself had been
inadvertently erased. The reasons read in part at paragraph 30 as follows:
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30 The Union argued that the Employer's breach of clause
22.19 [of the collective agreement] should result in the exclusion of all
of the evidence from the video. This should include the photocopy of
the single frame of the video as well as the testimony of the witnesses
who described what they saw on the video. For the most part, I agree,
the testimony which described what the witnesses saw on the video
should be excluded. The union was provided with a copy of the
photocopy of the single frame of the video and although it's low quality
makes it almost useless, it was provided in compliance with clause
22.19 and therefore is not excluded.
[18] The union submitted that in all the circumstances the managers’ evidence
relating to the content of the video is inadmissible and should be excluded.
[19] The employer first submitted that the evidence of the managers is relevant, which
is the test for admissibility. Second, the employer submitted that it is not hearsay
evidence, it is secondary evidence. The video itself would have been the "best-
evidence", or the primary evidence, and the witnesses’ observations of the tape
are the secondary evidence. It submitted that the fact that this testimony is
secondary evidence goes to its weight, not its admissibility. Further, a party is not
bound to use the best evidence; it may prove its case by secondary evidence.
The employer relied upon a number of authorities in which criminal courts have
admitted secondary evidence of what individuals had seen on a video in
circumstances where the video had been lost, destroyed or not preserved. Third,
the employer submitted that the probative value of the evidence outweighs any
prejudicial effect. It said that the Board has the authority to exclude evidence if its
prejudicial effect outweighs its probative value. On this latter point, the employer
submitted that any prejudice to the union because of the loss of the video may be
cured through cross-examination of the witnesses and use of witness statements
and notes in the cross-examination. Further, it is open to the union to call the
grievor to provide his account of what transpired. The employer said there was
no appearance of an unfair hearing by admitting the evidence of the managers
even if ultimately such evidence is given no weight. The employer submitted that
it is actual prejudice, not speculative prejudice, that the union must establish, and
it has failed to discharge that burden in seeking to exclude this evidence. It said
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that only at the end of the case, in final argument, would it be possible to weigh
whether there has been actual prejudice to the union. Finally, with respect to
prejudice, the employer said that the Board must consider prejudice to the
employer as well. It said that failing to admit relevant evidence, which addresses
the issues in dispute, would violate the employer's right to be heard and would be
a breach of natural justice. Such evidence has been admitted in many criminal
cases. In summary it said that the probative value of the evidence far outweighs
any prejudicial effect of not having the video available.
[20] Finally, the employer submitted that no other labor-relations rationale supports
the exclusion of this evidence. The loss of the video was not willful; there is no
right in the collective agreement to disclosure of documents and evidence, and in
the present circumstances a finding to exclude this evidence would change the
nature of arbitrations by imposing an evidentiary standard that is not currently
recognized.
[21] In reply, the union submitted that in the Calgary Co-Operative Association and
UCCC (Komicha) case the arbitrator did what the Court of Appeal in Larman
suggested by excluding the videotape evidence. It said I have the right to do the
same thing. The union also submitted that the arbitrator in Komicha accepted the
notion that the videotape was hearsay. It also submitted that in the Brampton
(City) v. Lam case the evidence of both Constable Coupland and the defendant
did not invoke any hearsay issues because they limited themselves to what they
saw and did not include any person’s gestures. It said here that the nature of the
allegations set out in the employer's Book of Documents at tabs 29 and 30 are
moving into that realm.
Analysis and Decision
[22] I start with consideration of the ruling of the Court of Appeal in OPSEU
(Larman). In my view, the effect of not admitting the evidence of the two
managers with respect to what they saw on the videotape would effectively bring
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the proceedings to a halt. Although the union is not asking directly for the
grievance to be allowed on the basis of the destruction of the videotape
evidence, that would be the effect. Accordingly, the concerns raised by the Court
of Appeal in Larman are alive on this motion before me. The court said the
following at paragraph 26:
26 A stay of proceedings is "an extraordinary remedy" for lost
evidence to be "granted only in the clearest of cases" for lost evidence
in criminal cases involving the breach of Charter rights: [R v. Carosella
(1997), 112 C.C.C. (3d) 289 (S.C.C.)] at para 52. When one turns from
the criminal law to the regime of civil or private law, and from staying a
criminal proceeding to granting a civil claim on the basis of the
inadvertent loss of evidence, the remedy is even more exceptional. I
agree with the appellant that the generally accepted principle in the
civil law context is that the destruction of documents is a procedural
matter that calls for procedural remedies .
. . .
[23] In my view it is necessary to consider the proposed evidence in the context of
whether or not it is "available". That is the error that the Court of Appeal found
the arbitrator in Larman fell into. That is, in Larman there was evidence available
from the employer, and the failure to permit the employer to call that evidence
amounted to a denial of natural justice. Accordingly, the options laid out by the
Court of Appeal as the remedy for the inadvertent destruction of evidence must
be considered in the context of what, if any, evidence is available to the employer
in this matter. For convenience, I again set out paragraph 27 from the Court of
Appeal’s decision which is as follows:
27. Inadvertent destruction of evidence can be remedied in a
variety of ways. An adverse inference can be drawn against the party
who bears the obligation to produce the document or evidence in
question: Coriale (Litigation Guardian of) [ v. Sisters of St. Joseph of
Sault Ste Marie (1998) 41 O.R. (3d) 347]. Similarly, the party failing to
produce relevant material may be precluded from relying on that or
related documents or evidence: [Werner v. Warner Auto-Marine Inc.
(1996), 3 C.P.C. (4th) 110 (Ont. C.A.)]. No case was cited to us for
the proposition that a claim or grievance can be allowed, without
hearing all the evidence that is available, on the ground that the
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responding party inadvertently failed to produce relevant
documents or evidence.
(emphasis added)
[24] In considering whether the evidence of what the managers saw on the videotape
in this matter is available because it is admissible it is essential to appreciate the
qualitative differences amongst the cases relied upon with respect to the content
of the video images. An important case relied upon by the union is R. v.
Khelawon [2006]2 S.C.R. 787. In that matter the allegation was that that an 81-
year-old resident of a nursing home had been beaten by the manager. The
resident made a videotaped statement at the police station that was not under
oath. This statement was admitted at trial, along with those of other residents
making similar allegations. The Supreme Court of Canada decided that although
the statement met the test of necessity, flowing from R. v. Khan, his videotaped
statement was not sufficiently trustworthy to meet the threshold of reliability. The
judgment in Khelawon thoroughly reviews the rule excluding hearsay. What
should not be lost sight of is that hearsay is an out-of-court statement. The Court
says the following, in part, at paragraph 2:
2. As a general principle, all relevant evidence is admissible. The rule
excluding hearsay is a well-established exception to this general
principle. While no single rationale underlines its historical
development, the central reason for the presumptive exclusion of
hearsay statements is the general inability to test their reliability.
Without the maker of the statement in court, it may be impossible to
inquire into that person's perception, memory, narration or sincerity.
. . .
[25] The video images in this case are of the purported actions of the grievor while he
was in the cab of the tunnel car. I am told that the evidence of the managers will
be to recount what they saw the grievor doing in the tunnel car cab. In my view,
this is materially different from videotaped hearsay statements being relied upon
for the truth of their contents. Manifestly, if someone were an eyewitness to
actions that happened in the street, they would be permitted to tell the finder of
fact what they had seen. The question here is whether it matters that they saw a
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video of the grievor's actions rather than personally witnessed them at the time
and place of the actions, in the context of the video no longer being available.
[26] The union has characterized the evidence of the managers as not being the best
or direct evidence, based upon which it should be ruled inadmissible. However, if
the video is considered in the context of it being the best evidence, the
authorities are clear that the best evidence rule is not an exclusionary rule. In the
absence of the best evidence it is open to a party to rely upon secondary
evidence. In R. v. Swartz, Papalia, Cotroni and Violi, supra, the Ontario Court of
Appeal noted the following distinction as set out in Halsbury 4th ed., Vol 17, p.8:
The rule itself, in its relatively modern form did not absolutely exclude
secondary evidence. It is stated by Lord Esher, M.R. in Lucas v.
Williams & Sons, (1892) 2 Q.B. at 116:
"Primary’ and ‘secondary’ evidence mean this: primary evidence is
evidence which the law requires to be given first; secondary
evidence is evidence which may be given in the absence of the
better evidence which the law requires to be given first, when a
proper explanation is given of the absence of that better evidence."
[27] In R. v. Newfoundland and Labrador Association of Public and Private
Employees the court cited with approval the following excerpt from Evidence and
Procedure in Canadian Labor Arbitration, (Gorsky, Usprich and Brandt, Carswell,
1994 at pages 11 – 54 to 11 – 55:
At times, one sees references to a best evidence rule in other than a
documentary context. What is then generally meant is a common-sense
principle that one ought to present the strongest evidence one can. For
example, eye-witness testimony is obviously preferable to proving the fact by
some piece of hearsay admitted under an exception. That is good practical
advice, but it is not an exclusionary rule. Even the courts, let alone an
arbitrator, will not exclude relevant evidence simply because better evidence
could have been called on the point. That a party does not use the seemingly
better evidence may arouse suspicion, which may then affect the arbitrator's
assessment of the party’s evidence, but that is the only risk.
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[28] Accordingly, there is no general bar to leading secondary evidence instead of the
best evidence. In the end it goes to the weight to be attached to the evidence at
the close the case.
[29] Evidence such as that proposed to be tendered here has been ruled admissible
in the criminal courts. In R. v. After Dark Enterprises, supra, the Alberta Court of
Appeal restored the decision of the Provincial Court judge who had admitted the
evidence of bylaw officers who had viewed a video tape that was then not
available at the trial. They were permitted to testify as to what they had seen on
the tape. In R. v. Pires, supra, the store clerk and a Police Constable had viewed
surveillance video that was not produced at the trial. The court found that the
best evidence rule did not preclude viva voce evidence of persons who observe
the video. It also found that “secondary evidence is admissible where the original
was later accidentally or in good faith lost or destroyed without the intention to
prevent its use as evidence.” (at par. 55.) With respect to the application of the
hearsay rule the court said as follows at paragraph 57:
The hearsay rule is not applicable in my view. The video footage was
real evidence: see R. v. Nikolovski (1996), 111 C.C.C. (3d) 403
(S.C.C.). If it had existed, it could have been played in court without
there being any objection based upon hearsay. While the witnesses
who testified about what they saw on the video did not themselves
observe the car accident, this does not make their evidence
inadmissible hearsay. If the video was properly admissible as real
evidence of what occurred, P.C. Barnacas and Mr. Shandhirasegara’s
testimony does not become hearsay because the video is not
available. Of course, their evidence is subject to my assessment of
weight, but it does not make their evidence inadmissible on this basis.
I should observe that any danger raised by the lack of the video
footage is compensated by the opportunity to fully cross-examine the
officer and clerk as to what they observed. The defense in this case
ably conducted this cross-examination
[30] I agree that the evidence seen on the video here was direct evidence, not
hearsay evidence. Similar conclusions are reached in R. v. Lapensee and
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Brampton City v. Lam, (supra). Paragraph 73 in the Brampton City case reads as
follows:
73 Moreover, both Cst. Coupland’s and the defendant's
testimony about what they'd observed on the video do not invoke any
hearsay issues. They had only describe what they had observed of the
physical acts or movements of objects on the video of the collision and
not of any persons gestures, which would imply a communicative
statement or message. As such, both there testimony can be
considered as admissible evidence, and will carry and be considered
for their appropriate weight.
[31] I disagree with the union submission that the documents set out at tabs 29 and
30 of the employer's Book of Documents necessarily are recounting gestures that
would be excluded as hearsay. The point is, that the evidence of the two
managers of what they saw on the video is admissible. The weight to be
accorded their evidence, for instance on the basis that it is uncorroborated
hearsay because it relates to gestures, is a matter to be argued at the close the
case.
[32] The overwhelming strength of the authorities is that such secondary evidence is
admissible when the trier of fact is satisfied that the original existed, has been
lost or destroyed and a proper explanation has been given of the absence of the
better evidence. Here, that explanation has been given and accepted by the
union.
[33] An exception in the case law is Calgary Co-Operative Assn. and UCCE, supra.
The existence of article 22.19 in that collective agreement distinguishes that case
from the others reviewed above. Article 22.19 there entitled the union to a copy
of all relevant evidence, including video surveillance evidence. It is clear from
paragraph 17 of this decision, above, that the existence of that provision in the
collective agreement in that case was central to the decision reached.
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[34] In addition, it is not clear to me that the arbitrator there accepted that the video
was hearsay evidence. The union relied on paragraph 36 for this proposition.
However, paragraph 31 indicates that the only evidence on the point of whether
Mr. Komicha had turned in tips to either one of the two cashiers on duty on the
day in question rested on the Gas Bar Manager having testified as to what the
cashiers had told him. That appears to be the hearsay evidence that was the
subject of the nonsuit application.
[35] I turn to whether the probative value of the evidence outweighs any prejudicial
effect. I agree with the thrust of the jurisprudence above that any prejudice to the
grievor can be overcome by the cross-examination of the managers on what they
saw and what could be seen from the vantage point of the video-camera in the
tunnel car cab. Such a cross-examination would be similar to that to which any
eyewitness would be subjected. The matter of prejudice must also be considered
from the employer's perspective. To rule that the managers’ evidence is
inadmissible would be contrary to the jurisprudence and deny the employer it's
right to make its case on the evidence that it has. To do so would be tantamount
to deciding the grievance without hearing all the evidence that is available which
would be contrary to the decision of the Court of Appeal in OPSEU (Larman),
supra, and contrary to the principals of natural justice. Clearly, the probative
value of this evidence outweighs any prejudicial effect. There is no prejudice to
the union in allowing the employer to call the direct evidence that it has.
[36] In all of the circumstances, the union’s motion that the proposed evidence of the
managers is inadmissible is dismissed.
Dated at Toronto, Ontario this 22nd day of January 2016.
Daniel Harris, Vice Chair