Facts:

The case involves Januaria A. Rivera (petitioner) and United Laboratories, Inc. (respondent). Rivera began her employment with UNILAB on April 7, 1958, as a senior manufacturing pharmacist and later became the Director of the Manufacturing Division. In 1988, after completing 30 years of service, she was retired effective December 31, 1988, under UNILAB's retirement plan, which provided for compulsory retirement at age 60 or after 30 years of service. Rivera's retirement benefits were calculated based on her monthly salary of P28,000.00, amounting to a total of P1,047,331.33, which was withdrawn from the retirement fund and deposited into Trust Fund C, allowing her to make withdrawals as needed.

Despite her retirement, Rivera continued to work for UNILAB and was promoted to Assistant Vice-President in January 1989, earning a monthly salary of P50,034.00. She worked in this capacity until the end of 1992, at which point she was again declared retired from employment, ...

Facts:

Employment and Retirement Background

• Januaria A. Rivera (Rivera) began employment with United Laboratories, Inc. (UNILAB) on April 7, 1958, and rose to the position of Director of the Manufacturing Division.
• In 1959, UNILAB established a comprehensive retirement plan, which mandated compulsory retirement upon reaching age 60 or completing 30 years of service, whichever came first.
• Rivera completed 30 years of service and was compulsorily retired on December 31, 1988. Her retirement benefits, based on her salary at the time, totaled P1,047,331.33, which was transferred to a special account (Trust Fund C) for her withdrawals.

Post-Retirement Employment

• After her retirement, Rivera continued working with UNILAB and was promoted to Assistant Vice-President in 1989, with a higher salary. She served in this capacity until the end of 1992, when she retired again, as evidenced by a personnel action notice.
• From 1993 to 1994, Rivera worked as a consultant for ARMCO and Fil-Asia, UNILAB’s sister companies, performing tasks related to UNILAB.

Retirement Plan Amendment

• On December 16, 1992, UNILAB amended its retirement plan, increasing retirement benefits from one month to 1.5 months of terminal basic salary per year of service.
• Rivera demanded additional retirement benefits based on the amended plan, but UNILAB denied her request, stating the amendment did not apply to her as she had retired in 1988.

Legal Proceedings

• Rivera filed a complaint with the National Labor Relations Commission (NLRC) on August 9, 1996, seeking unpaid retirement pay differential.
• The Labor Arbiter dismissed the complaint, ruling that Rivera’s claim had prescribed. The NLRC affirmed this decision.
• The Court of Appeals (CA) reversed the NLRC, finding that Rivera’s claim had not prescribed, but remanded the case to the Labor Arbiter for further hearing.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Retirement and Post-Retirement Employment: Rivera’s retirement in 1988 was mandatory under UNILAB’s retirement plan. Her continued employment after 1988 was consensual and did not reinstate her coverage under the retirement plan.
2. Applicability of Amended Retirement Plan: The 1992 amendment to the retirement plan did not apply to Rivera, as she had already retired in 1988.
3. Retirement Pay Law (R.A. No. 7641): Rivera did not qualify under the Retirement Pay Law, as she had less than five years of service after the law took effect and was not covered by any retirement plan during that period.
4. Consultancy Services: Rivera’s work with ARMCO and Fil-Asia from 1993 to 1994 was as a consultant, not as an employee of UNILAB. Thus, these years could not be included in her service record for retirement benefits.
5. Fairness and Equity: The Court found no inequitable treatment by UNILAB, as Rivera was given her just due under the specific rules that applied to her retirement.