Case Summary (G.R. No. 215281)
Factual Antecedents
In 2012, the private respondents filed a complaint for illegal dismissal against "RAF Mansion Hotel Old Management and New Management and Victoriano Ewayan." Subsequently, they amended the complaint to include De Roca as a co-respondent. Although summons was initially sent through registered mail to De Roca, it was returned undelivered. Summons were later personally served to him, but he failed to attend subsequent hearings, leading the labor arbiter to allow the respondents to submit their position paper. The labor arbiter decided in favor of the respondents, ordering De Roca to pay back wages and other monetary awards, ultimately denying his motion to dismiss based on the lack of an employer-employee relationship.
Ruling of the Labor Arbiter
The labor arbiter ruled that De Roca's motion to dismiss was filed beyond the period provided by the NLRC Rules of Procedure and reiterated that he had failed to challenge the evidence submitted by the respondents. The ruling noted that De Roca's assertion regarding the absence of jurisdiction due to the alleged lack of an employer-employee relationship did not hold as he did not provide evidence to support his claims.
Ruling of the National Labor Relations Commission
De Roca's petition for annulment of the labor arbiter's judgment was dismissed by the NLRC due to its filing being beyond the prescribed period. The NLRC observed that procedural timelines were strictly adhered to and faulted De Roca for not having submitted his position paper or appealing in a timely manner.
Ruling of the Court of Appeals
De Roca subsequently petitioned for certiorari with the Court of Appeals, arguing that he was improperly included as a respondent merely due to his ownership of the hotel premises, while the actual employer was Victoriano Ewayan, who operated the hotel. The Court of Appeals dismissed the petition on grounds of timeliness and procedural adherence, noting that the jurisdictional issue concerning employer-employee relationships had not been adequately resolved in De Roca's favor.
Petitioner’s Arguments
De Roca’s arguments centered on the assertion that he was not the employer of the respondents and thus not subject to the jurisdiction of labor tribunals. He emphasized that the respondents were employed by Ewayan's company, Oceanic Travel and Tours Agency. De Roca claimed his inclusion as a party in the complaint was an afterthought due to Ewayan's disappearance. He contended that the labor tribunals failed to adequately consider the evidence regarding the lease agreement he had with Oceanic and thus did not establish any employment relationship between him and the private respondents.
Respondents’ Arguments
The respondents opposed De Roca's claims, asserting that he had indeed acted as their employer since he owned the hotel premises and failed to challenge his liability. They maintained that the labor arbiter had jurisdiction over De Roca as he was part of the management structure of the hotel, particularly following Ewayan's alleged abscondment. They contended that the absence of an appeal from De Roca rendered the labor arbiter's decision final and binding.
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...continue readingCase Syllabus (G.R. No. 215281)
Background of the Case
- This case arises from a Petition for Review on Certiorari filed by Rolando De Roca, seeking to overturn the June 19, 2014 Decision and the October 28, 2014 Resolution of the Court of Appeals (CA).
- The CA dismissed De Roca’s Petition for Certiorari in CA-G.R. SP No. 127974 and denied his Motion for Reconsideration.
Factual Antecedents
- In 2012, private respondents filed a complaint for illegal dismissal against “RAF Mansion Hotel Old Management and New Management and Victoriano Ewayan.” Later, Rolando De Roca was included as a co-respondent.
- Summons sent to De Roca through registered mail was returned. A conference was scheduled, but only the complainants attended, leading to another summons being served personally to De Roca on March 14, 2012.
- De Roca failed to attend subsequent hearings, prompting the labor arbiter to direct the submission of position papers by the complainants.
- On April 18, 2012, the complainants submitted their position paper. De Roca filed a Motion to Dismiss on April 18, 2012, claiming lack of jurisdiction based on an alleged absence of an employer-employee relationship.
- The labor arbiter ruled on June 29, 2012, ordering De Roca to pay backwages and other monetary awards, and denied his motion to dismiss for being filed late.
Ruling of the Labor Arbiter
- The labor arbiter held that De Roca's Motion to Dismiss was inadmissible due to late filing, based on the Revised 2011 NLRC Rules of Procedure.
- The decision indicated a lack of evidence from De Roca to counter the claims made by the complainants.
- The labor arbiter found all respondents liable for