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A-527-8i
André Giroux (Applicant) v.
Canada Employment and Immigration Commis sion (Respondent)
and
Deputy Attorney General of Canada (Mis -en- cause)
INDEXED AS: GIROUX V. CANADA (CANADA EMPLOYMENT ANL IMMIGRATION COMMISSION) (C.A.)
Court of Appeal, Pratte, Lacombe and Desjardins JJ.—Montréal, March 2; Ottawa, April 15, 1988.
Unemployment insurance Quebec construction worker receiving compulsory annual vacation pay under Construction Decree from Office de la construction du Québec Payments received in December 1985 and 1986 during periods of lay-off and when in receipt of unemployment insurance benefits Payments not earnings within Unemployment Insurance Regu lations, but repayment of savings Construction workers in Quebec governed by Construction Decree, deserving same treatment as those in Ontario governed by collective agree ments Phrase "in respect of his severance from employ ment" in Regulations, s. 57(3)(h) referring both to money payable under policy and under collective agreement Com mission's power to make regulations providing for allocation of earnings including power to determine week in which earn ings made.
This was an application to set aside the decision of a board of referees that annual vacation pay received by the applicant from the Office de la construction du Québec in December 1985 and 1986, while he was laid off and receiving unemploy ment insurance benefits, was earnings. The applicant's terms of employment were determined by Quebec's Construction Decree, which requires an employer to pay a percentage of an employee's wages to the Office de la construction du Québec as annual vacation pay. The money is then paid to employees on specified dates. The applicant argued that the money was not earnings within section 57 of the Regulations. He relied on Bryden v. Canada Employment and Immigration Commission, [1982] I S.C.R. 443, wherein the Supreme Court of Canada held that vacation pay paid under a collective agreement between the employee's union and the Boilermakers Contrac tors' Association was a repayment of savings. The applicant disputed Daigle v. Employment and Immigration Commission, a decision of the Federal Court of Appeal, which distinguished the Bryden case on the grounds that in Bryden employees could apply to withdraw the amounts before their vacation period, and the payments were made under a contract, not a legislative
decree like Quebec's Construction Decree. The Federal Court of Appeal followed Bryden in Vennari v. Canada (Canada Employment and Immigration Commission), [1987] 3 F.C. 129, where vacation pay was paid in the same circumstances as Bryden. Secondly, the applicant argued that the money was not earnings because it had been paid to him in the circumstances described in paragraph 57(3)(h). That paragraph provides that where the content of an employer's written policy respecting moneys payable on severance is established by documents that show that such policy actually existed prior to December 31, 1984, any moneys payable pursuant to that agreement or policy "in respect of his severance from employment" including vaca tion pay, are not earnings. The applicant argued that the vacation pay was paid under a collective agreement in effect prior to December 31, 1984; therefore it was not earnings even though it was not paid in relation to his severance from employment. The applicant relied on Stone J.'s interpretation of paragraph 57(3)(h) in Vennari that the words "in respect of his severance from employment" refer only to money payable under a policy, and not money payable under a collective agreement. Thirdly, he submitted that if the amounts received were earnings, they were earnings for the weeks during which they were earned and could not be allocated to other weeks. He relied on a statement of Thurlow C.J. in Vennari for this argument.
Held, the appeal should be allowed.
The compulsory annual vacation pay was not earnings within section 57 of the Regulations. The Federal Court of Appeal had erred in distinguishing Daigle from the Bryden case. Although the Quebec Construction Decree is a document of a legislative nature, it is based on a freely negotiated collective agreement. The terms of employment provided in a collective agreement are imposed on an employee just as those provided in a decree are imposed on him. The fact that under the decree employees can only claim payment of vacation pay on specified dates is not sufficient to conclude that the money is not held on the employee's behalf. That he is entitled to interest on the money the Office receives from employers indicates that the money is being held on the employee's behalf. Construction workers in Ontario and Quebec should be treated the same way.
As to the second argument, as was indicated in Vigneault v. Canada (Canada Employment and Immigration Commission), [ 1989] 1 F.C. 294, Vennari was wrongly decided on this point.
As to the third issue, Thurlow C.J.'s reasoning in Vennari did not take into consideration the power of the Commission under the Act to allocate earnings, including the power to determine
the week in which earnings were made. When earnings are tc be allocated to a week of unemployment under section 58 of the Regulations, such earnings are deemed to be earnings for that week even if they were payment for work done previously. The power to allocate given to the Commission by the Act is in spitc of the fact that in reality an employee earns all money paid tc him by his employer by working.
STATUTES AND REGULATIONS JUDICIALLY CONSIDERED
An Act respecting labour relations in the construction industry, R.S.Q., c. R-20.
Construction Decree, R.R.Q. 1981, c. R-20, r. 5, ss. 20.01, 20.06, 20.07.
Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28. Unemployment Insurance Act, 1971, S.C. 1970-7l-72, c. 48, ss. 26(2), 91.
Unemployment Insurance Regulations, C.R.C., c. 1576, ss. 57 (as am. by SOR/85-288, s. 1), 58(13) (as am. idem, s. 2).
CASES JUDICIALLY CONSIDERED FOLLOWED:
Bryden v. Canada Employment and Immigration Com mission, [1981] 2 F.C. 91 (C.A.); rev'd [1982] 1 S.C.R. 443.
NOT FOLLOWED:
Daigle v. Employment and Immigration Commission, A-547-83, Pratte J., judgment dated 19/1/84, F.C.A., not reported; Vennari v. Canada (Canada Employment and Immigration Commission), [1987] 3 F.C. 129 (C.A.).
CONSIDERED:
Unemployment Insurance Commission v. Serge Baril, CUB-4604.
REFERRED TO:
Vigneault v. Canada (Canada Employment and Immi gration Commission), [1989] 1 F.C. 294 (C.A.).
COUNSEL:
Guy Martin for applicant.
Carole Bureau and Guy LeBlanc for respon
dent.
SOLICITORS:
Sauvé, Ménard & Associés, Montréal, for applicant.
Deputy Attorney General of Canada for respondent.
The following is the English version of the reasons for judgment rendered by
PRATTE J.: The applicant has applied under section 28 of the Federal Court Act [R.S.C. 1970 (2nd Supp.), c. 10] to have a decision of a board of referees established under section 91 of the Unem ployment Insurance Act, 1971 [S.C. 1970-71-72, c. 48] set aside. The decision of the board was that money received by the applicant in December 1985 and 1986 from the Office de la construction du Québec as annual vacation pay was earnings within the meaning of section 57 of the Unemploy ment Insurance Regulations [C.R.C., c. 1576], and therefore had to be allocated as provided in subsection 58(13) [as am. by SOR/85-288, s. 2] of the Regulations.
The applicant is a carpenter. In 1985 and 1986 he worked for a building contractor, and his terms of employment were determined by the Construc tion Decree (R.R.Q. 1981, c. R-20, r. 5) adopted by the government of Quebec under An Act respecting labour relations in the construction industry (R.S.Q., c. R-20). This decree provides that every employee is entitled each year to four weeks of compulsory vacation and in addition to paying its employee's salary the employer must credit them each week with annual vacation pay in the amount of six per cent of wages earned during the week. Each month, the employer must pay the amounts so credited to each employee to the Office de la construction du Québec, which is in turn required to pay the money to the employees on the dates specified. These provisions are contained in sections 20.01 and 20.06 of the decree:
20.01. Compulsory annual vacations: Each year, every employee is entitled to 4 weeks' annual compulsory vacation to be taken as follows:
(1) Summer: All construction job sites must close down during the last 2 full calendar weeks in July ....
20.06. Vacation pay and general pay:
(1) Amount: At the end of each week, the employer must credit each employee with 10% of wages earned during the week, such amount representing the vacation and general hol-
iday pay, or 6% for the compulsory annual vacation and 4% for general holidays.
(2) Obligation of the employer: The employer must submit a monthly report to the Board, showing amounts so credited to each of his employees.
(3) Qualifying period: There are 2 qualifying periods:
(a) first: from 1 January to 30 April;
(b) second: from 1 May to 31 December.
(4) Payment for compulsory vacation and paid general holidays:
(a) The Board must pay the employee the amount collected for the first qualifying period by means of a cheque sent to the last known address of the employee concerned within the first 8 days of the month of December of the current year.
(b) The Board must pay the employer [sic] the amount collected for the second qualifying period by means of a cheque sent to the last known address of the employee concerned within the first 8 days of the month of July of the current year.
(e) No one may claim before 10 December or 10 July as the case may be, the pay for compulsory annual vacations and general holidays.
(d) Despite the provisions of paragraph c, following the death of an employee, his legal heirs may claim the compulsory annual vacation pay and the general holiday pay of the said employee.
20.07. Interests: Interests on the amounts collected with respect to compulsory annual vacations and general holidays that have not been taken and within the limits of the Act must be remitted to construction employees at a pro rata of the amounts that they receive.
The applicant was laid off as a result of a work shortage on December 13, 1985. He was recalled to work on February 10, 1986. He was again laid off, for the same reason, on the following Decem- ber 12, and he returned to work on March 1, 1987. During these two periods of unemployment, the applicant claimed and received unemployment in surance benefits. During December 1985 and 1986, the Office de la construction du Québec paid him the compulsory annual vacation pay to which he was entitled under the decree. The applicant accordingly received $295.67 in December 1985 and $390 in December 1986. The respondent Commission determined that this was vacation pay paid with respect to the periods of winter vacation provided in the decree, and as a result it allocated the money in accordance with paragraph 58(13)(a) of the Unemployment Insurance Regulations.' The applicant disputed this decision
It is useful to set out here subsection 58(13) of the Regula tions as it then read, in its entirety:
(Continued on next page)
and appealed it to the Board of Referees. His appeal was dismissed, and he appealed to this Court.
The applicant argued first that the money that he received from the Office de la construction was not "earnings" within the meaning of section 57 of the Unemployment Insurance Regulations, and accordingly that the Commission did not have the power to allocate this money under section 58. Applicant based his submission on two arguments. First, he said that the money in question had been received and held on his behalf by the Office de la construction du Québec, so that when the Office paid it to him it was simply repaying his savings to him. Secondly, he argued that the money in ques tion had been paid to him in the circumstances described in paragraph 57(3)(h) [as am. by SOR/ 85-288, s. 1] of the Regulations, and accordingly that it did not constitute earnings.
The applicant also submitted that in any event, if we suppose that the pay he received constituted earnings, it was earnings for the weeks of work during which they were earned, so that they could not be allocated to any weeks other than those.
I would like to examine each of these argu ments, beginning with the latter, in reverse order to the order I have just used.
(Continued from previous page)
58....
(13) Vacation pay of a claimant shall be allocated
(a) where it is paid or payable in respect of a specific vacation period, to a number of consecutive weeks beginning with the first week and ending with the last week of the vacation period;
(b) where it is not in respect of a specific vacation period and it is paid or payable in respect of a lay-off or separation from employment, to a number of consecutive weeks beginning with the week in which the lay-off or separation occurs, in such a way that the claimant's earnings in each of those weeks, except the last, are equal to the weekly rate of his normal earnings from his employer; and
(c) in any other case, to a number of consecutive weeks beginning with the week in which it is paid or payable in such a way that the amount of vacation pay allocated to each of those weeks, except the last, is equal to the weekly rate of the claimant's normal earnings from his employer.
1. If annual vacation pay is earnings, is it earnings in the weeks of work or of unemployment?
While it is important in this case to determine how to allocate the annual vacation pay received by the applicant, subsection 26(2) of the Act provides that the amount of unemployment insur ance benefit must be reduced when the claimant receives earnings in a week of unemployment. 2
The applicant says that subsection 26(2) only applies in cases where the claimant has earnings for a time that falls in a week of unemployment. In the case at bar, he continues, the pay received was earnings not for periods of unemployment, but for periods of work, because the claimant earned it while working. As a result, according to applicant, this pay could not be allocated to other periods than those in which it was earned, because the Commission does not have the power to allocate earnings to a week of unemployment which were in fact earnings for a week of work.
The applicant bases this reasoning, which is difficult to grasp, on the opinion of Chief Justice Thurlow in Vennari v. Canada (Canada Employ ment and Immigration Commission). 3 Vennari had received vacation pay in circumstances that were analogous to those in the case at bar. The Chief Justice stated that if the vacation pay were earnings, it was earnings for the weeks of work during which it had been earned, and as a result section 26 did not apply.
I must say, with a great deal of hesitation, that I do not find the Chief Justice's reasoning to be convincing. In my opinion, it does not take into consideration the power of the Commission under
2 Subsection 26(2) reads as follows:
26....
(2) If a claimant has earnings in respect of any time that falls in his waiting period, an amount not exceeding such earnings may, as prescribed, be deducted from the benefits payable in respect of the first three weeks for which benefits are otherwise payable.
3 [1987] 3 F.C. 129 (C.A.).
the Act to allocate earnings. When paragraph 58(q) gives the Commission the power to make regulations providing for the allocation of earnings to weeks, 4 in my opinion, it gives it the power to make regulations permitting it to determine the week in which earnings were made. Accordingly, when earnings are to be allocated to a week of unemployment under section 58 of the Regula tions, such earnings are deemed to be earnings for that week even if, in fact, they were in payment for work done previously. To argue the contrary appears to me to be to deny the Commission the power to allocate that the Act has given it, because in reality an employee earns all money paid to him by his employer, by working.
2. Paragraph 57(3)(h) of the Regulations
In order for section 26 of the Act to be applied, of course, the claimant must have received earn ings. In section 57 of the Regulations, the Com mission has defined what constitutes earnings for the purposes of section 26; in subsection 57(3) it has provided that certain moneys received by the claimant are not earnings, including, inter alia, moneys described as follows in paragraph 57(3)(h):
57. (3) ...
(h) subject to subsection (3.1), where
(i) the effective date of commencement of a formal labour- management agreement made specifically in respect of a plant closure or a workforce reduction or the effective date of commencement of a collective agreement is prior to Decem- ber 31, 1984, or
(ii) the content of an employer's written policy respecting moneys payable on severance of employment is established by documents that show that such policy actually existed prior to December 31, 1984,
any moneys that become payable to an employee pursuant to that agreement or policy in respect of his severance from employment, including severance pay, vacation pay, wages in lieu of notice and moneys payable in respect of other accumulated credits, during the period beginning on March 31, 1985 and ending on the earlier of March 26, 1988 and the
4 Paragraph 58(q) of the Act reads as follows:
58. The Commission may, with the approval of the Gover
nor in Council, make regulations
(q) defining and determining earnings for benefit pur poses, determining the amount of such earnings, provid ing for the allocation of such earnings to weeks and determining the average weekly insurable earnings in the qualifying weeks of claimants;
originally established expiry date of the agreement or policy;...
The applicant contends that the pay he received was paid to him under a collective agreement (which was extended by the Decree) in effect before December 31, 1984; accordingly, he argued, this pay is not earnings, even though it is admitted that it was not paid to him in relation to severance from his employment. According to the applicant, the words "in respect of his severance from employment" in paragraph 57(3)(h) refer only to money payable under a policy, and not money payable under a collective agreement. The appli cant bases this interpretation on the judgment of Mr. Justice Stone in the Vennari case.'
It is true that in Vennari Mr. Justice Stone adopted this interpretation of paragraph 57(3)(h). However, as I have had occasion to note, 6 he based this finding solely on the English version of the Regulations. If the French version of this provision had been brought to his attention, he would not have decided as he did, because the French text both dispels any ambiguity that the English ver sion might contain and cannot be reconciled with the interpretation he adopted. In light of this, it is clear that Vennari was wrongly decided on this point.
3. Was the pay paid to applicant by the Office de la construction the applicant's savings?
Finally, I shall deal with applicant's main argu ment, that is, that the annual vacation pay that he received from the Office de la construction was not earnings because it was in reality money that he had saved, the Office having received and kept it on his behalf.
This is not the first time that we have been asked to consider the manner in which to allocate vacation pay received during a period of unem ployment by a worker covered by the Quebec Construction Decree. Nor is it the first time that we have heard the argument that I have just set
5 Supra, footnote 3, at p. 142.
6 See Vigneault v. Canada (Canada Employment and Immi gration Commission), [1989] 1 F.C. 294 (C.A.).
out. It is primarily Umpires who have been asked to rule on this point; they have decided on many occasions that this pay should be allocated accord ing to subsection 173(13) of the Regulations (which later became subsection 57(13)). In 1977, in CUB-4604 [Unemployment Insurance Com mission v. Serge Baril], Mr. Justice Marceau, who was then a judge of the Trial Division and was sitting as an Umpire, explained this case law as follows [at page 5]:
First, this income from employment is not paid to the employee until it is remitted by the Board. One might at first be hesitant about this point and wonder whether the Board should not be regarded as an agent of the employee which has been instructed to receive money for him and then to act rather like a bank. Upon reflection, however, it is clear that this is not the case. The Board acts solely as instructed by the Act, which provides for a payment in two stages: from the employer to the Board, freeing the debtor of his obligation; and from the Board to the employee, cancelling the employee's credit. The employ er's debt is payable throughout the year but the employee's corresponding credit is not claimable until later, on specified dates. This clearly requires the presence of a third party. It is a most unusual situation but this is how the Act intended it to be and under these conditions the powers of the third party cannot be regarded as coming tacitly from one of the other two parties: they come solely from the Act. It is clear that the employee has no direct and immediately payable claim to vacation pay until the date specified in the Decree and that the money involved is not paid to him until it is remitted to him by the Board.
A similar problem with respect to vacation pay received by a worker in Ontario was submitted to this Court and then to the Supreme Court of Canada in Bryden v. Canada Employment and Immigration Commission.' The vacation pay in question in that case, which had been received by an employee named Bryden during a period of unemployment, had been paid to him not under the Quebec Construction Decree, but rather under a collective agreement between the Union of which he was a member and the Boilermakers Contrac tors' Association. This agreement, which governed the terms of employment for employees working in various provinces, provided that the employers who were members of the Association would pay vaca tion pay to each employee based on the amount of his gross wages, and that, except in Ontario, such pay had to be included in the employee's weekly earnings. The agreement added that Ontario employers, such as Bryden's employer, had to pay
[1981] 2 F.C. 91 (C.A.); rev'd [1982] 1 S.C.R. 443.
this pay each month into a trust fund established and managed by the Union. The trust agreement provided that these payments would be received from the various employers by the fund in trust "on behalf of each employee", and that the trust ees would administer these moneys and would normally distribute them to each employee on about June 15 and November 15. The trust agree ment added that an employee could apply to the trustees at any time during the year to remit his vacation pay to him on another date.
Accordingly, Bryden had received the vacation pay provided for in the trust agreement and in the collective agreement from the trustees during a period of unemployment. The Commission had allocated this money in accordance with subsection 173(16) of the Regulations, concerning the alloca tion of vacation pay, to the week during which the money was paid to Bryden and to the following weeks.
Both in this Court and in the Supreme Court, Bryden contended that the trustees had received payment of the money representing his vacation pay on his, Bryden's, behalf, and accordingly that by paying him the money the trustees had merely been returning his own savings to him. This argu ment was rejected by this Court, which found that Bryden had received his vacation pay only at the time when it had been paid to him by the trustees. That decision was reversed by the Supreme Court of Canada, which held that at the moment when the vacation pay was received by the trustees Bryden had acquired sufficient interest in this money that it could be said that at that moment the money represented his savings which the trus tees were holding and administering on his behalf. Thus by paying Bryden the trustees were not paying him vacation pay, but rather were remit ting his savings to him. In making this finding, the Court noted that in that case, as in this, the employer had deducted from the amounts payable to the trustees the income tax payable by the employee, as well as his share of unemployment insurance premiums; it also noted that according to the trust agreement the vacation pay that was normally payable on fixed dates could be applied
for by the employees on another date as an exception.
Following this decision of the Supreme Court, we were called upon in the Daigle case 8 to decide on the allocation of compulsory vacation pay received by an unemployed employee under the Quebec Construction Decree. Daigle relied on the Bryden decision in support of his argument that the money that he had received from the Office de la construction du Quebec could not be allocated like vacation pay, because it actually represented his own savings. Speaking for the Court, I rejected this argument for the following reasons [at page 2]:
This would be a persuasive argument if the case at bar were identical to Bryden, but that is not so. It is true that in Bryden, as in the case at bar, amounts were paid by the employer to a third party which was then to pay them to the employees. In Bryden, however, the employees were entitled to withdraw these amounts before their vacation period: that is not the case here. Further, the case at bar does not involve, as did Bryden, payments made pursuant to an arrangement of a purely con tractual nature: these are payments made under a decree of a legislative nature, which sets a compulsory date for vacation in the construction industry and provides procedures for employees in that industry to receive vacation pay.
In 1985, clearly intending to avoid seeing the Bryden decision applied in future, the Commission amended subsection 58(14) of the Regulations so as to provide for allocation, where "vacation pay is paid into a trust", of money paid to a claimant in accordance with the terms of the trust. This amendment was in effect when the Vennari case arose. 9 Like Bryden, Vennari was from Ontario. He was also covered by a collective agreement similar to the one governing Bryden's terms of employment, and he had received vacation pay in the same circumstances as Bryden. The Commis sion had allocated this money in the manner pro vided in the new subsection 58(14) of the Regula tions. The Court set aside the decision of the Umpire, who had upheld the allocation. It stated, first, as the Supreme Court had decided in Bryden, that by paying the employee the trustees had
s Daigle v. Employment and Immigration Commission,
unreported decision dated January 19, 1984, No. A-547-83.
9 Supra, footnote 3.
merely returned his savings to him; accordingly it decided that this payment was not earnings within the meaning of section 57 of the Regulations and that it could not be allocated under section 58 because the only money that could be allocated under that section was earnings within the mean ing of section 57.
The applicant today relies on the Bryden and Vennari decisions and states that, contrary to what we decided in Daigle, these decisions must be applied to compulsory vacation pay paid to employees under the Quebec Construction Decree. In other words, the applicant disputes our decision in Daigle.
This issue must be examined carefully. It is certainly desirable that the jurisprudence of this Court demonstrate an element of consistency, and accordingly we normally follow the decisions that we have rendered in the past. It is even more important, however, that everyone coming before the courts in situations that are truly identical should be dealt with in the same way. Accordingly, if the effect of our decision in Daigle was to create an artificial distinction between construction work ers in Quebec and in Ontario, we should put an end to this undesirable situation and acknowledge that we erred in the Daigle case.
I must admit that, upon reflection, the reasons that I gave for "distinguishing" the Daigle case from the Bryden case appear to me today not to be convincing.
It is true that the vacation pay received by Bryden was payable under a collective agreement, while the pay received by Daigle was payable under a decree. But was this really a significant difference? Certainly the decree is a document of a legislative nature, but it is based on a freely negotiated collective agreement. Furthermore, in so far as the employee is concerned, the terms of employment provided in a collective agreement are imposed on him just as those provided in the decree are imposed on him.
It is also true that Bryden was entitled under the trust agreement to withdraw his vacation pay on a different date from the date normally provided. This was certainly an indication that the trustee held this money on the employee's behalf. In Quebec, under the decree, employees can claim payment of the annual vacation pay only on the dates provided. The reason for this may be that in Quebec, in the construction industry, the decree imposes compulsory annual vacation, the date of which is established by the decree. We cannot conclude from this difference that the money held by the Office de la construction which it receives from employers is not held on the employee's behalf. The evidence is that, as the decree states, "Interests on the amounts collected with respect to compulsory annual vacations ... that have not been taken and within the limits of the Act [sic] must be remitted to construction employees at a pro rata of the amounts that they receive." If the employees are entitled to interest on the money that the Office receives from employers, it appears to me that this is because the Office is holding this money on their behalf.
I find that I erred in stating in the Daigle case that the Bryden decision did not apply to annual vacation pay paid under the Quebec Construction Decree. It appears to me that the rights of a construction worker in Quebec to the money held by the Office de la construction are similar, if not identical, to those of workers in Ontario who are governed by a collective agreement like the agree ments in issue in Bryden and Vennari. According ly, they should be treated in the same way.
The respondent, of course, argued the contrary. She did not, however, attempt to demonstrate that the "distinctions" that I made in the Daigle case between the situation of construction workers in Quebec and in Ontario were meaningful. Her pri mary argument was to point out that if the Bryden case were applied in Quebec, construction workers who receive annual vacation pay during a period of unemployment will be entitled to unemployment insurance benefits, despite the fact that they are receiving exactly the same financial benefits as they would have received if they were still employed. The respondent submitted that this would be an unacceptable result.
This is certainly, in my opinion as well, a highly unusual result. However, it is a necessary conse quence of the Bryden decision, which we are bound to apply regardless of the results.
I would allow the appeal, I would set aside the decision impugned and refer the matter back to the Board of Referees for determination, this time on the basis that the compulsory annual vacation pay received by applicant from the Office de la construction du Québec is not earnings within the meaning of section 57 of the Unemployment In surance Regulations.
LACOMBE J.: I concur. DESJARDINS J.: I concur.
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