Clause de mobilité dans le contrat de travail

  • Posted by Loïc Panhaleux
  • On 18 juillet 2008
  • 497 Comments

Une clause de mobilité est une clause insérée dans un contrat de travail dont l’objet est de permettre à l’employeur de demander au salarié de changer de secteur géographique. Il faut que cette clause soit acceptée par le salarié. La jurisprudence considère que la clause de mobilité incluse dans un contrat non signé par le salarié lui est inopposable (Soc, 2 avril 1998, bull. Civ. V, n° 196).code du travail

Par ailleurs, la clause de mobilité doit définir de façon précise sa zone géographique d’application (soc. 7, juin 2006, Bull. Civ. V, N° 209 ; Soc, 12 juill. 2006, bull. civ. V N° 241).

La clause de mobilité peut-elle aussi trouver sa source dans la convention collective applicable, sans la moindre mention dans le contrat individuel de travail ? Cette idée a été remise en cause par la Cour de cassation dans un arrêt du 24 janvier 2008. La Cour de cassation considère qu' »une clause de mobilité doit définir de façon précise sa zone géographique d’application » et que « l’article 61 de la convention collective nationale du personnel des bureaux d’études techniques, des cabinets d’ingénieurs-conseils et des sociétés de conseils, dite SYNTEC, du 1er janvier 1988, qui se borne à énoncer que toute modification du lieu de travail comprenant un changement de résidence fixe, qui n’est pas accepté par le salarié, est considéré, à défaut de solution de compromis, comme un licenciement et réglé comme tel, ne saurait constituer une clause de mobilité licite directement applicable au salarié en l’absence de clause contractuelle de mobilité » et finalement que « la cour d’appel, qui a constaté que le contrat de travail du salarié ne contenait pas de clause de mobilité, a décidé que le licenciement était sans cause réelle et sérieuse ».

En toute hypothèse, la question se pose de savoir si un tel changement constitue une modification du contrat de travail. On considère qu’il y a pas modification du contrat de travail mais simple changement lorsque le salarié est affecté une tâche différente de celle qu’il exerçait antérieurement mais correspondant sa situation (Cass. Soc. 10 mai 1999, 10 oct. 2001, 24 avril 2001). Les critères d’appréciation sont les suivants : qualification, classification, rémunération, degré de subordination la direction générale, place dans l’organigramme.

La Cour de cassation, dans un arrêt du 6 mai 1997, à propos d’un attaché commercial, a considéré que « la détermination du secteur d’activité étant un élément essentiel du contrat liant les parties, la modification unilatérale d’une telle clause, refusée par l’intéressé, rend la rupture invoquée par le salarié imputable la société ».

Mais un autre arrêt de la Cour de cassation du 3 mai mérite d’être pris en compte. Il a été rendu à propos d’une société qui avait ajouté un télex et une balance électronique aux machines déj commercialisées par ses VRP mais réduit en conséquence leur secteur d’activité, ce qui se traduisait par une baisse des commissions. Cette modification du contrat avait été refusée par un VRP. Licencié de ce fait, il avait alors contesté le caractère réel et sérieux de son licenciement. La Cour de cassation a finalement tranché dans les termes suivants : « Mais attendu que la cour d’appel, faisant application de la législation antérieure la loi du 2 août 1989, a constaté que la modification du contrat de travail proposée par l’employeur et refusée par le salarié avait été décidée en raison d’une réorganisation générale de la politique commerciale de l’entreprise résultant de la mise sur le marché de nouveaux produits et que cette réorganisation était commandée par la nécessité d’assurer la pérennité de la société confrontée à des changements technologiques ; qu’en l’état de ces constatations et énonciations elle a pu décider que le refus du salarié d’accepter la modification de son contrat de travail constituait une cause réelle et sérieuse de licenciement ; que le moyen n’est pas fondé ».

Le salarié doit donc être prudent avant de refuser la mobilité. Son refus peut en effet constituer une cause de licenciement. Selon la Cour de cassation, le refus, par le salarié dont le contrat de travail contient une clause de mobilité, de la modification de son lieu de travail constitue en principe un manquement à ses obligations contractuelles mais ne caractérise pas à lui seul une faute grave ( Soc. 23 janv. 2008).

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