G.R. No. 190809 - De La Salle Araneta University vs. Bernardo

De La Salle-Araneta University (DLS-AU), a non-stock, non-profit educational institution, is the petitioner, while Juanito C. Bernardo, a part‑time lecturer, is the respondent.
The dispute revolves around Bernardo’s claim for retirement benefits, which DLS-AU and its Executive Vice-President, Dr. Oscar Bautista, denied on the basis that Bernardo was employed on a fixed-term, part‑time basis and was ineligible for such benefits under the institution’s policy and agreements.

Bernardo began teaching as a part‑time professional lecturer on June 1, 1974 at DLS-AU (formerly Araneta University Foundation) for an hourly rate of P20.00.
He rendered his services for two semesters and a summer session in the 1974‑1975 school year, then took a leave of absence from June 1, 1975 to October 31, 1977 while he was assigned by the government abroad.
Upon his return in 1977, Bernardo resumed teaching until his last contract expired on October 12, 2003.

On November 8, 2003, DLS-AU informed Bernardo via telephone that his contract would not be renewed due to the implementation of a retirement age limit, effectively terminating his employment even though he continued teaching beyond the compulsory age of 65.
At the time of termination, Bernardo was earning P246.50 per hour.

Bernardo, aged 75 at the time of his retirement, sought advice from the Department of Labor and Employment (DOLE) and was informed in letters (dated January 20, 2004 and February 3, 2004) that he was entitled to retirement benefits under Republic Act No. 7641 (the “New Retirement Law”).
Despite these advisories, Dr. Bautista stated in a letter dated February 12, 2004 that as a part‑time employee, Bernardo was not entitled to any separation or retirement pay, citing university policy and the Collective Bargaining Agreement (CBA) which restricted benefits to full‑time permanent faculty.

Bernardo filed a complaint on February 26, 2004 with the National Labor Relations Commission (NLRC) for non‑payment of retirement benefits and damages.
The Labor Arbiter initially dismissed his complaint on the ground that his claim was barred by prescription as he should have claimed his benefits upon reaching age 65.
Bernardo appealed, leading the NLRC to reverse the Labor Arbiter’s decision on June 30, 2008, holding that his cause of action accrued only upon being informed of non‑renewal, and thus his claim was timely.
The Court of Appeals subsequently affirmed in its Decision dated June 29, 2009, and further resolved a Motion for Reconsideration on January 4, 2010.

DLS-AU then elevated the matter to the Supreme Court through a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
The petition contended that (i) part‑time employees are excluded from retirement benefits under Republic Act No. 7641, and (ii) Bernardo’s claim, being filed ten years after his effective separation, was barred by prescription under Article 291 of the Labor Code.

DLS-AU and Dr. Bautista maintained that Bernardo, as a part‑time, fixed‑term employee, never acquired a permanent status which is a requisition for retirement benefits.
They argued that the compulsory retirement age is 65, and since Bernardo had exceeded that age, his cause of action accrued at 65 and was time‑barred by the three‑year prescriptive period under Article 291 of the Labor Code.
Bernardo, however, argued that there was an implied agreement that allowed him to continue teaching beyond 65, and that his cause of action accrued only when DLS-AU notified him that his services would no longer be required.
He further asserted that the equitable doctrine of estoppel prevented DLS-AU from later invoking prescription since they themselves continued to employ him well beyond the compulsory retirement age.

Whether part‑time employees, such as Bernardo, are excluded from the coverage of those entitled to retirement benefits under Republic Act No. 7641.
Whether a claim for retirement benefits filed beyond the three‑year period provided under Article 291 of the Labor Code is duly barred by prescription, notwithstanding the continuous extension of employment beyond the compulsory retirement age.