Rolando de Roca v. Eduardo C. Dabuyan

Summary

This case involved hotel workers who filed illegal dismissal claims against the building owner-lessor after their true employer absconded. Petitioner Rolando De Roca owned RAF Mansion Hotel building which he leased to Oceanic Travel and Tour Agency operated by Victoriano Ewayan. When respondent workers were dismissed, they initially sued the hotel management and Ewayan, but later impleaded petitioner as co-respondent when Ewayan disappeared. The Labor Arbiter held petitioner liable despite his motion to dismiss claiming lack of employer-employee relationship, ruling the motion was filed beyond the reglementary period. The NLRC and Court of Appeals upheld this on procedural grounds. However, the Supreme Court reversed, finding that substantive justice should prevail over procedural technicalities. The Court held that petitioner, as mere building owner-lessor under a lease agreement, had no employer-employee relationship with respondents and could not be held liable for their claims. The decision emphasized that allowing recovery from petitioner would constitute unjust enrichment and declared the Labor Arbiter's decision null and void for lack of jurisdiction.