De La Salle Araneta University v. Bernardo
REITERATIONFacts
The Antecedents: Respondent Juanito C. Bernardo (Bernardo) was employed as a part-time professional lecturer by De La Salle-Araneta University (DLS-AU) from June 1, 1974, with intermittent service until October 12, 2003. Bernardo was informed on November 8, 2003, that his contract would not be renewed due to the implementation of a retirement age limit, as he was 75 years old. The Department of Labor and Employment (DOLE) opined that Bernardo was entitled to retirement benefits under Republic Act No. 7641. However, DLS-AU, through Dr. Oscar Bautista, denied the claim, stating that only full-time permanent faculty with at least five years of service were entitled to benefits, and as a part-time lecturer with fixed-term contracts, Bernardo did not qualify. Procedural History: Bernardo filed a complaint for retirement benefits and damages. The Labor Arbiter dismissed the complaint, ruling that Bernardo's claim was barred by prescription as he was past the compulsory retirement age of 65 and had not filed within three years of reaching it. The National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, finding Bernardo entitled to retirement benefits and holding that his cause of action accrued on November 8, 2003, when his employment was effectively terminated, and that DLS-AU was estopped from claiming prescription. The Court of Appeals affirmed the NLRC ruling. DLS-AU filed a Petition for Review on Certiorari before the Supreme Court. The Petition: DLS-AU sought the annulment of the Court of Appeals' decision, raising two main issues: (1) whether part-time employees are excluded from the coverage of Republic Act No. 7641, and (2) whether Bernardo's claim for retirement benefits was barred by prescription.
Issue(s)
Whether part-time employees are excluded from the coverage of Republic Act No. 7641. Whether Bernardo's claim for retirement benefits was barred by prescription.
Ruling
The Supreme Court dismissed the petition for lack of merit, affirming the decision of the Court of Appeals. The Court held that Bernardo, as a part-time employee with fixed-term employment, is entitled to retirement benefits under Republic Act No. 7641. Furthermore, the Court ruled that Bernardo's claim for retirement benefits was not barred by prescription, as his cause of action accrued upon the termination of his extended employment, and the principle of estoppel applied against DLS-AU.
Ratio Decidendi
On the issue of whether part-time employees are excluded from the coverage of Republic Act No. 7641: The Court held that Republic Act No. 7641, also known as the "New Retirement Law," applies to all employees in the private sector, regardless of their position, designation, or status, and irrespective of the method by which their wages are paid. The law explicitly enumerates its exemptions, which do not include part-time employees. The Implementing Rules and a Labor Advisory from the Department of Labor and Employment further clarify that part-time employees are included within the coverage of the law. The Court applied the principle of expressio unius est exclusio alterius, stating that the express mention of certain exemptions implies the exclusion of others not mentioned. Therefore, Bernardo, as a part-time employee, is entitled to retirement benefits under the law. On the issue of prescription of Bernardo's claim for retirement benefits: The Court ruled that Bernardo's claim was not barred by prescription. While the compulsory retirement age is 65, DLS-AU had continuously extended Bernardo's employment for 10 years beyond that age. The Court established that Bernardo's right to retirement benefits and DLS-AU's obligation to pay them were established under the Labor Code. However, a violation of Bernardo's right, constituting a cause of action, only occurred after DLS-AU informed him of the non-renewal of his contract and subsequently denied his claim for retirement benefits. Therefore, the cause of action accrued not upon reaching 65, but upon the termination of his extended employment and the denial of his claim. Furthermore, the Court invoked the equitable doctrine of estoppel against DLS-AU, as the university's conduct in continuously offering employment beyond the compulsory retirement age led Bernardo to believe he was still employed and to defer his claim, preventing DLS-AU from later asserting prescription.
Main Doctrine
A part-time employee with fixed-term employment is entitled to retirement benefits under Republic Act No. 7641, and the cause of action for such benefits accrues upon the termination of the extended employment, not upon reaching the compulsory retirement age, especially when the employer's conduct invokes the principle of estoppel.