Case Digest (G.R. No. 223621)
Facts:
Father Saturnino Urios University (FSUU) Inc., and/or Rev. Fr. John Christian U. Young v. Atty. Ruben B. Curaza, G.R. No. 223621, June 10, 2020, Supreme Court Third Division, Leonen, J., writing for the Court. The Catholic Educational Association of the Philippines intervened.Atty. Ruben B. Curaza was engaged by Father Saturnino Urios University beginning in the second semester of S.Y. 1979–1980 as a teacher of commercial law and subsequently taught in several colleges of the University, later becoming a pioneering Law College professor. On November 21, 2008 he applied for early retirement under the University’s Personnel Policy and the Retirement Pay Law; after receiving no favorable action, he followed up and was told the University did not grant retirement benefits to part-time teachers. He reiterated his application on March 5, 2009, attaching a Labor Advisory on the Retirement Pay Law, but the University still did not act by the time he reached age 60.
On June 25, 2010, Atty. Curaza filed a complaint for retirement benefits, damages and attorney’s fees before the National Labor Relations Commission (NLRC) Regional Arbitration Branch XIII in Butuan City. The University contended he was only a part-time instructor paid per hour/load/semester, excluded from the faculty association’s Collective Bargaining Agreement and not covered by Republic Act No. 7641. The University also argued gaps in his teaching years and denied illegal dismissal.
The Executive Labor Arbiter, in a December 28, 2010 Decision, ruled that part-time employees are entitled to retirement benefits under Republic Act No. 7641, awarded retirement pay computed on the average monthly pay for the last five years multiplied by 24 years of credited service, and granted attorney’s fees. The NLRC affirmed that decision in its December 29, 2011 Resolution. The Court of Appeals, in CA‑G.R. SP No. 04973‑MIN (Decision penned June 5, 2015), affirmed the rulings but modified the credited years of service to 22 years after examining teaching-load records; it held RA 7641 covers part‑time employees and that a Collective Bargaining Agreement cannot contravene the law.
FSUU and its president filed a Petition for Review on Certiorari (Rule 45) to the Supreme Court; the petition was initially denied for failure to show reversible error, but after a Motion for Reconsideration the petition was reinstated. The Catholic Educational Association of the Philippines moved to intervene, alleging its retirement plan covers only regular full‑ti...(Subscriber-Only)
Issues:
- Are part-time employees entitled to retirement benefits under Republic Act No. 7641?
- Was the Court of Appeals correct in computing respondent Atty. Curaza’s creditable years of service as 22 years for purposes of r...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)