Case Summary (G.R. No. 190809)
Petition and Background
DLS-AU seeks to annul the Decision of the Court of Appeals affirming a ruling of the National Labor Relations Commission (NLRC) which found that Bernardo was entitled to retirement benefits after 27 years of service. Bernardo began working at DLS-AU on June 1, 1974, and continued until October 12, 2003, when he was informed of his retirement due to reaching 75 years of age.
Employment Contract and Claims
Bernardo’s complaint for retirement benefits, filed on February 26, 2004, was based on his long tenure at DLS-AU, despite being employed as a part-time lecturer with fixed-term contracts. The university contended that only full-time, permanent staff with at least five years of service were eligible for such benefits, based on both internal policy and Collective Bargaining Agreements (CBAs).
NLRC Decision
Initially, the Labor Arbiter dismissed Bernardo’s claim due to prescription, asserting that his cause of action for retirement benefits accrued when he reached the compulsory retirement age of 65. The appeal to the NLRC reversed this decision, concluding that Bernardo’s retirement was only effective upon notification from DLS-AU about the non-renewal of his contract.
Court of Appeals Ruling
The Court of Appeals upheld the NLRC’s ruling, highlighting that part-time employees are entitled to retirement benefits under RA 7641. The appellate court emphasized the remedial nature of labor laws, advocating for a liberal interpretation that favors the employee in instances of ambiguity.
Issues of Appeal
DLS-AU, in its petition, raised two primary issues: whether part-time employees are excluded from retirement benefits under RA 7641, and whether Bernardo's claim had already prescribed as per Article 291 of the Labor Code thereby barring his entitlement based on timing of claims.
Supreme Court Findings
The Supreme Court ruled in favor of Bernardo, asserting that part-time employees are not explicitly excluded from the coverage of RA 7641. It reaffirmed that retirement benefits aim to provide financial support and reward loyalty, thus implying that all workers, regardless of employment type, should be protected under the law unless expressly stated otherwise.
Cause of Action and Prescription
The Supreme Court held that Bernardo's cause of action accrued not when he turned 65 but when DLS-AU informed him that his contract woul
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Background of the Case
- De La Salle-Araneta University (DLS-AU) filed a Petition for Review on Certiorari under Rule 45, seeking to annul and reverse the Court of Appeals' Decision dated June 29, 2009, and Resolution dated January 4, 2010.
- The Court of Appeals affirmed the National Labor Relations Commission (NLRC) Decision, which had reversed the Labor Arbiter's dismissal of Juanito C. Bernardo's claim for retirement benefits.
- Bernardo worked as a part-time lecturer at DLS-AU from June 1, 1974, until October 12, 2003, at an hourly rate that increased over the years.
Facts of the Case
- Bernardo began his employment as a part-time lecturer in 1974, with a brief leave from 1975 to 1977.
- He continued working until he was informed on November 8, 2003, that he could no longer teach due to the university's retirement age policy, as he was 75 years old.
- The Department of Labor and Employment (DOLE) advised Bernardo in early 2004 that he was entitled to retirement benefits under Republic Act No. 7641.
Contentions of the Parties
- DLS-AU claimed that Bernardo, as a part-time faculty member, was not entitled to retirement benefits due to the university’s policy and the Collective Bargaining Agreement (CBA), which favored full-time permanent faculty.
- Bernardo argued that he was entitled to retirement benefits under Republic Act No. 7641, citing his lengthy service and the absence