Case Summary (G.R. No. 162580)
Background and Employment History
Atty. Curaza was employed by the University starting in the 1979-1980 school year, teaching various courses across different departments, including the College of Law. In 2008, he submitted a letter applying for early retirement but was informed that only full-time employees were eligible for such benefits. His employment status was categorized as part-time, with payments based on teaching load.
Initial Application for Retirement
Following an unresponsive application process, Atty. Curaza filed a complaint against the University in 2010, claiming entitlement to retirement benefits along with damages and attorney's fees. The University countered that he was merely a part-time instructor, thereby disqualifying him from receiving retirement benefits under Republic Act No. 7641.
Arbiter's Decision
The Executive Labor Arbiter ruled in favor of Atty. Curaza in December 2010, asserting that under Republic Act No. 7641, part-time employees are entitled to retirement benefits. This decision emphasized that the law superseded any company policy that would deny such benefits.
Affirmation by Higher Authorities
The National Labor Relations Commission (NLRC) upheld the Arbiter's decision, as did the Court of Appeals, which reasoned that there was no applicable applicable agreement or retirement plan that excluded Atty. Curaza. The court determined that the exclusion of part-time employees from the Collective Bargaining Agreement violated the provisions of Republic Act No. 7641.
Modification of Service Computation
The Court of Appeals modified the Arbiter's decision regarding the computation of Atty. Curaza's years of service from 24 years to 22 years based on his actual teaching history. The ruling stated that the teaching load summary evidenced Curaza's employment only during specific school years, affirming that the University could not challenge the established years of service based on prior records.
Legal Arguments of Petitioners
The petitioners challenged the applicability of Republic Act No. 7641 to part-time teachers, citing prior case law indicating that only regular permanent employees qualify for retirement benefits. They referred to the Manual of Regulations for Private Higher Education and argued that the law was designed to reward loyalty and long-term service, which they contended part-time statuses do not meet.
Denial of Petitions
In resolving the core issue, the court rejected the argument that part-time employees should not be entitled to retirement benefits. It ruled that Republic Act No. 7641 broadly applies to all employees within the private sector, making no explicit exceptions for part-time employees. The court maintained that the law and it
...continue readingCase Syllabus (G.R. No. 162580)
Case Background
- This case involves a Petition for Review on Certiorari filed by Father Saturnino Urios University, Inc. and Rev. Fr. John Christian U. Young, challenging the Court of Appeals’ ruling regarding Atty. Ruben B. Curaza’s eligibility for retirement benefits under Republic Act No. 7641.
- Atty. Curaza was hired by the University in 1979 to teach commercial law and later held positions in various colleges within the University, including the College of Law.
- On November 21, 2008, Atty. Curaza applied for early retirement, but the University did not respond to his application.
- Following up on his application and receiving no favorable action, he filed a complaint on June 25, 2010, against the University, its president, and vice president for retirement benefits, damages, and attorney fees.
University’s Position
- The University claimed that Atty. Curaza was a part-time instructor and not a permanent employee, thus ineligible for retirement benefits.
- It noted that he was compensated based on his teaching load and received his last gross salary of P1,400.00 for a three-unit subject in the College of Engineering during the second semester of 2008-2009.
- The University argued that its Collective Bargaining Agreement excluded part-time faculty from retirement benefits, and similarly, Republic Act No. 7641 does not apply to part-time instructors.
- Furthermore, they contended that Atty. Curaza had gaps in his teaching service, specifically not teaching during certain academic years, and thus was not entitled to damages.
Labor Arbiter's Decision
- The Executive Labor Arbiter ruled in favor of Atty. Curaza on December 28, 2010, stating that under Republic Act No. 7641, part-time employees are entitled to retirement benefits, and that the law supersedes company policy.
- The Arbiter concluded that Atty. Curaza, having turned 60 an