Case Digest (G.R. No. 120802)
Facts:
The case involves Jose T. Capili, Jr. (petitioner) and the National Labor Relations Commission (NLRC) and the University of Mindanao (respondents). Capili was employed as a college instructor at the University of Mindanao starting in November 1982. On July 2, 1993, the university informed him that he would be eligible for retirement upon reaching the age of 60 on August 18, 1993, according to their retirement program. In response, Capili asserted that he did not wish to retire and intended to continue working until the compulsory retirement age of 65, as stipulated in the Rules Implementing the Labor Code. The university maintained that it had the authority to retire him at 60 under its retirement plan, which it claimed applied to all employees, including non-members. Capili perceived this insistence as constructive dismissal and filed a complaint for illegal dismissal with the Regional Arbitration Branch No. XI of the NLRC in Davao City, seeking reinstatement, back wages, an...
Case Digest (G.R. No. 120802)
Facts:
Employment and Retirement Notice:
- Petitioner Jose T. Capili, Jr. was employed by the University of Mindanao (UM) as a college instructor in November 1982.
- On 2 July 1993, UM informed Capili that he would be eligible for retirement upon reaching the age of 60 on 18 August 1993, citing UM's retirement program and the law.
- Capili responded on 5 August 1993, stating that under Section 4, Rule II, Book VI of the Rules Implementing the Labor Code, he had the option to retire at 65 and chose to continue working until then.
UM's Position:
- UM replied on 10 August 1993, asserting that under its retirement plan, it could retire employees at 60. It argued that the option to retire at 65 only applied in the absence of a retirement plan.
Complaint for Illegal Dismissal:
- Capili perceived UM's insistence as constructive dismissal and filed a complaint for illegal dismissal before the NLRC Regional Arbitration Branch No. XI in Davao City. He sought reinstatement, back wages, wage differentials, 13th month pay differentials, moral and exemplary damages, and attorney’s fees.
Labor Arbiter's Decision:
- On 18 April 1994, Labor Arbiter Newton Sancho ruled in favor of UM, dismissing Capili’s complaint. The Arbiter held that UM’s retirement plan applied to all employees, including non-members, and that Capili’s reliance on Republic Act No. 7641 was misplaced.
Appeal to NLRC:
- Capili appealed to the NLRC on 10 May 1994. UM moved to dismiss the appeal for being filed out of time.
- During the appeal, Capili received partial and later full payment of his retirement benefits. UM argued that this rendered the appeal moot and academic.
NLRC's Ruling:
- On 31 March 1995, the NLRC dismissed the appeal, holding that Capili’s acceptance of retirement benefits estopped him from pursuing his claims. It also ruled that UM could not force Capili to retire at 60 unless justified, but the issue became moot due to Capili’s acceptance of benefits.
Issue:
- Whether an instructor of a private educational institution may be compelled to retire at the age of 60 under UM’s retirement plan.
- Whether Capili’s acceptance of retirement benefits estopped him from pursuing his complaint for illegal dismissal.
- Whether UM’s retirement plan applied to Capili, a non-member of the plan.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)