HomeMy WebLinkAbout2003-3741.Augustine.05-05-16 Decision
Crown Employees Commission de ~~
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
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GSB# 2003-3741
UNION# 02-48
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
CanadIan Umon of PublIc Employees - Local 1750
(AugustIne) Union
- and -
The Crown In RIght of Ontano
(Workplace Safety and Insurance Board) Employer
BEFORE Dan Hams Vice-Chair
FOR THE UNION Ian Thompson
CanadIan Umon of PublIc Employees
FOR THE EMPLOYER WillIam R. Gale
Grosman, Grosman & Gale LLP
BarrIsters and SOlICItorS
and
GurJIt Brar
Counsel
Workplace Safety and Insurance Board
HEARING May 9 2005
DeCISIon
ThIS IS an Intenm deCISIOn regardIng the admISSIbIlIty of a statement taken In the course
of an Internal InVestIgatIOn by the Workplace Safety & Insurance Board (hereafter
WSIB or employer) of an alleged fraud.
The gnevor was a claims adJudIcator wIth the WSIB He was dIscharged from hIS
posItIOn because the employer belIeved he had conspIred wIth another employee a
payment specIalIst, and an InJured worker to defraud the WSIB
As part of ItS InVestIgatIOn Into the alleged fraud, the employer's InVestIgatIOn branch
IntervIewed the payment specIalIst who IS Said to have admItted hIS part In the scheme
and made statements ImplIcatIng the gnevor Part of the IntervIew was taped and a
transcnpt was prepared. I have neIther heard nor read the statement. The heanng on the
ments has commenced and the umon now asks for an early rulIng on the admIssIbIlIty of
the statement. The employer has IndIcated that It wIll seek to have the recorded statement
and the transcnpt admItted Into eVIdence through the InVestIgator It does not Intend to
call the maker of the statement. SeemIngly the payment specIalIst has subsequently
repudIated the statement.
The umon has obJectIOns to the statement regardIng ItS completeness and recordIng
qualIty However at thIS Juncture It only argued that the statement IS InadmISSIble as
hearsay gIven the senousness of the consequences to the gnevor and the cnmInal nature
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of the allegatIOns The umon says that the admIssIOn of thIS hearsay statement IS not
necessary nor IS the statement relIable
The employer says that the statement IS necessary because the partIcIpants In the alleged
fraud are the only ones who have the knowledge necessary to prove the fraud, and thIS
statement represents the knowledge of one of those partIcIpants The statement IS Said to
be relIable because It IS a tape recordIng of a confessIOn and a confessIOn IS a relIable
statement.
In my VIew the statement may not be admItted Into eVIdence In the manner proposed by
the employer FIrst, and most Importantly It IS not necessary to admIt the statement In
the manner proposed. The payment specIalIst IS avaIlable and may be called by the
employer to gIve dIrect eVIdence There are tIme tested eVIdentIary rules at the
employer's dIsposal should he turn out to be a hostIle wItness or If a need should anse to
deal wIth any eVIdence he mIght gIve that contradIcts the statement.
Second, the statement IS not reasonably relIable Hearsay statements may be safely
admItted for the truth of theIr contents where In the cIrcumstances, the statements are
reasonably relIable Here we are consIdenng a repudIated confessIOn that IS relIed on by
the employer because It IS Said to ImplIcate the gnevor a co-conspIrator Such eVIdence
IS patently "unrelIable" In the sense that that word IS used In cases such as R v Khan
[1990] 2 S C.R. 531 The maker of the statement IS an Interested party wIth acute self-
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awareness of the CIrcumstances WIthIn whIch he IS embrOIled. ThIS IS not a statement for
whIch cross-eXamInatIOn would be superfluous
InR v Smith [1992] 2 S C.R. 915 at paragraph 29 the folloWIng excerpts are set out
from Wigmore on Evidence (2nd edItIOn 1923) sectIOn 1420
Of the criterion of necessity Wigmore stated.
Where the test of cross-examination is impossible of application, by reason of the declarant's
death or some other cause rendering him now unavailable as a witness on the stand, we are
faced with the alternatives of receiving his statements without that test, or of leaving his
knowledge altogether unutilized. The question arises whether the interests of truth would suffer
more by adopting the latter or the former alternative [I]t is clear at least that, so far as in a
given instance some substitute for cross-examination is found to have been present, there is
ground for making an exception. [Emphasis in original.]
And of the companion principle of reliability -- the circumstantial guarantee of trustworthiness -- the
following:
There are many situations in which it can be easily seen that such a required test [i.e. cross-
examination] would add little as a security because its purposes had been already substantially
accomplished. If a statement has been made under such circumstances that even a sceptical
caution would look upon it as trustworthy (in the ordinary instance), in a high degree of
probability it [page930] would be pedantic to insist on a test whose chief object is already
secured.
CertaInly I have the authonty to admIt hearsay eVIdence pursuant to s 48(12)(f) of the
Labour Relations Act, 1995 However such dIscretIOn must be properly exercIsed. The
proposed eVIdence touches on central facts In Issue Where dIrect eVIdence eXIsts, It
should be called and subJected to cross-eXamInatIOn. It IS no answer that the umon could
call the payment specIalIst, have hIm declared hostIle and then cross-examIne hIm The
employer bears the burden of proof In thIS matter I agree wIth the approach taken by
ArbItrator SurdykowskI, In Hamilton Health Sciences and C UF.E. Local 4800 (2004)
133 L.A.C (4th) 139 (Surdykowsk) at paragraph 15
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[15] I am therefore satisfied that there were witnesses who could have given direct evidence for the Union
with respect to the matters in issue, and that the hearsay evidence that the Union sought to rely on instead of
calling that direct evidence is therefore inadmissible For the same reasons, even if the hearsay evidence was
admissible, I would give it no weight.
For the foregoIng reasons, the umon's obJectIOn to the tendenng of the statement of the payment
specIalIst through the WSIB InVestIgator IS upheld.
Dated at Toronto thIS 16th day of May 2005