Charles Kevin C.

Absalon
JD 4A

Rolando de Roca vs Eduardo C. Dabuyan, et al.

G.R. No. 215281 March 05, 2018

FACTS:

Dabuyan, et al. filed a complaint for illegal dismissal against “RAF Mansion Hotel Oki
Management and New Management and Victoriano Erawan”. Later, they amended the complaint
and included petitioner de Roca as co-respondent. Summons were served on de Roca but it was
returned. Another summons was issued and personally served to the petitioner. Despite service
of summons, petitioner did not attend the subsequent hearings prompting the labor to direct
Dabuyan, et al. to submit their position paper.

Upon filing their position paper, de Roca filed his motion to dismiss on the ground of
lack of jurisdiction, on the same day. He alleged that, while he is the owner of RAF Mansion
Hotel Building, the same was being leased by Victoriano Ewayan, the owner of Oceanics Travel
and Tour Agency.

De Roca claims that Ewayan was the employer of Dabuyan, et al. Consequently, he
asserted that there was no employer-employee relationship between him and Dabuyan, et al. and
the labor arbiter has no jurisdiction.

The LA rendered a decision directing de Roca to pay backwages and other monetary
awards to Dabuyan, et al.

De Roca then filed a petition for annulment of judgment on the ground of jurisdiction
before the NLRC. However, it was dismissed because it was filed beyond the allowable period.

De Roca filed a Petition for Certiorari before the Court of Appeals, but the latter
dismissed the petition. Petitioner then filed a motion for reconsideration but also denied. Hence,
this petition.

ISSUE:

Whether or not a lessor of a hotel business can be held liable for the labor obligation of
the lessee who also use the name of the hotel in his operations.

HELD:

No. The Supreme Court granted de Roca’s petition.

Charles Kevin C. Absalon
JD 4A

Contracts take effect only between the parties, their assigns and heirs, except in case
where the lights and obligations arising from the contract are not transmissible by their nature, or
by stipulation or by provision of law.

Contract of employment between Dabuyan, et al. on the one hand, and Oceanic and
Ewayan on the other, is effective only between them; it does not extend to Roca, who is not a
party thereto. His only role is a lessor of the premises which Oceanic leased to operate the hotel;
he cannot be deemed as Dabuyan et al.’s employer –not even under the pretext that he took over
as the “new management” of the hotel operated by Oceanic. There simply is no truth to such
claim. Thus, to allow Dabuyan, et al. to recover their monetary claims from Roca would
necessarily result in their unjust enrichment.