DE ROCA v. DABUYAN, et. al, G.R. No. 215281 | 2018
827 Phil. 98
FIRST DIVISIONG.R. No. 215281. March 05, 2018
ROLANDO DE ROCA, PETITIONER,
VS.
EDUARDO C. DABUYAN, JENNIFER A. BRANZUELA, JENNYLYN A. RICARTE, AND HERMINIGILDO F. SABANATE, RESPONDENTS.
Ponente: DEL CASTILLO, J.:
Doctrine:
There is unjust enrichment 'when a person unjustly retains a benefit to the loss of another, or when a person retains money or property of another against the fundamental principles of justice, equity and good conscience.' The principle of unjust enrichment requires two conditions: (1) that a person is benefited without a valid basis or justification, and (2) that such benefit is derived at the expense of another.
The main objective of the principle against unjust enrichment is to prevent one from enriching himself at the expense of another without just cause or consideration. x x x
"In rendering justice, courts have always been, as they ought to be, conscientiously guided by the norm that on the balance, technicalities take a backseat against substantive rights, and not the other way around."[25] In short, substantive law outweighs procedural technicalities as in this case.
Indeed, where as here, there is a strong showing that grave miscarriage of justice would result from the strict application of the [r]ules, we will not hesitate to relax the same in the interest of substantial justice. It bears stressing that the rules of procedure are merely tools designed to facilitate the attainment of justice. They were conceived and promulgated to effectively aid the court in the dispensation of justice. Courts are not slaves to or robots of technical rules, shorn of judicial discretion. In rendering justice, courts have always been as they ought to be, conscientiously guided by the norm that on the balance, technicalities take a backseat against substantive rights, and not the other way around. Thus, if the application of the Rules would tend to frustrate rather than promote justice, it is always within our power to suspend the rules, or except a particular case from its operation.
Synopsis:
The petitioner, was accused of illegal dismissal. Private respondents had filed a complaint in 2012 against the "RAF Mansion Hotel Old Management and New Management and Victoriano Ewayan," but they amended the complaint and included de Roca as a co-respondent. De Roca received a summons through registered mail, but it was returned. Another summons was issued and personally served to him by the bailiff of the NLRC. De Roca did not attend the subsequent hearings, prompting the labor arbiter to direct private respondents to submit their position paper, which they did.
De Roca filed a motion to dismiss the case for lack of jurisdiction, arguing that he was not the employer of the private respondents. He claimed that he was only the owner of the building, which was being leased by Ewayan, the owner of Oceanics Travel and Tour Agency. De Roca asserted that Ewayan was the employer of the private respondents and that the labor arbiter had no jurisdiction over him. However, the labor arbiter rendered a decision directing de Roca, among others, to pay back wages and other monetary awards to private respondents. The labor arbiter also denied de Roca's motion to dismiss for having been filed beyond the reglementary period.
De Roca filed a petition for annulment of judgment on the ground of lack of jurisdiction before the NLRC, but it was dismissed because it was also filed beyond the 10-day reglementary period prescribed under Section 3, Rule XII of the 2011 NLRC Rules of Procedure. The Court of Appeals affirmed the decision.
The issue was whether or not the Court of Appeals erred in affirming that de Roca was solidarily liable with Ewayan/Oceanic to the private respondents. The court ruled that de Roca was not liable because there was no employer-employee relationship between him and the private respondents. All throughout the proceedings, de Roca had insisted that he did not hire the respondents, nor did he pay their salaries, exercise supervision or control over them, or have the power to terminate their services. He attached copies of a lease agreement executed by him and Oceanic, represented by Ewayan through his attorney-in-fact, to support his claim.
The contract of employment between respondents and Oceanic and Ewayan is effective only between them, and it does not extend to de Roca, who is not a party to the contract. De Roca's only role is as lessor of the premises which Oceanic leased to operate as a hotel. To allow respondents to recover their monetary claims from de Roca would result in their unjust enrichment. The rules of procedure are tools designed to facilitate the attainment of justice, and they were not meant to shackle the court's discretion in rendering justice. The court, therefore, decided that substantive law outweighs procedural technicalities in this case.
Nature of petition:
This Petition for Review on Certiorari seeks to set aside the June 19, 2014 Decision and October 28, 2014 Resolution of the Court of Appeals (CA) dismissing the Petition for Certiorari in CA-G.R. SP No. 127974 and denying herein petitioner's Motion for Reconsideration, respectively.
Dispositive portion:
WHEREFORE, the Petition is GRANTED. The June 19,2014 Decision and October 28, 2014 Resolution of the Court of Appeals in CA-G.R. SP No. 127974 are REVERSED and SET ASlDE. NLRC-NCR-Case No. 02-02490-12 is ordered DISMISSED, but only as against petitioner Rolando De Roca.