· De La Salle Araneta University vs. Juanito C.
Bernardo GR# 190809- February 13, 2017
FACTS:
On February 26, 2004, Bernardo filed a complaint against De La Salle-Araneta University (DLS-AU) and its
manager, Dr. Oscar Bautista, seeking retirement benefits. Bernardo had worked as a part-time lecturer at
DLS-AU since 1974. In 2003, at 75 years old, he was informed that he could no longer teach due to the
university's retirement age policy. DLS-AU denied his request for retirement benefits, citing his part-time
status. Bernardo then filed a complaint with the National Labor Relations Commission (NLRC). The Labor
Arbiter initially dismissed his case, arguing that he should have claimed benefits at age 65. The NLRC
reversed this, ruling that Bernardo was entitled to benefits under Republic Act No. 7641, which applies
to part-time employees. The NLRC decided that his claim was timely, as it accrued when his employment
ended in 2003. The Court of Appeals upheld the NLRC's decision, stating that part-time employees are
not excluded from retirement benefits. The court also applied estoppel against DLS-AU for allowing
Bernardo to work beyond the retirement age. This led Bernardo to believe he could claim benefits later.
The Court of Appeals dismissed DLS-AU's petition and denied their motion for reconsideration.
Ultimately, Bernardo was awarded retirement benefits.
ISSUE: WHETHER OR NOT PART-TIME EMPLOYEES ARE EXCLUDED FROM THE COVERAGE OF THOSE
ENTITLED TO RETIREMENT BENEFITS UNDER REPUBLIC ACT NO. [7641].
RULING:
YES. The Court emphasized that retirement benefits are meant to help employees enjoy their remaining
years by easing financial burdens and rewarding their loyalty. In this case, De La Salle-Araneta University
(DLS-AU) denied Bernardo's claim for retirement benefits, arguing that only full-time faculty were
entitled under university policy. However, the Court found that Republic Act No. 7641 ensures
retirement benefits for all employees, including part-time workers like Bernardo, who are not covered by
any retirement plan. The law applies to private-sector employees, excluding only those in specific
exempted categories. Given that Bernardo met the age and service requirements, the Court ruled he was
entitled to retirement benefits. Additionally, since his employment was extended beyond the
compulsory retirement age, his right to claim these benefits accrued when his employment finally
ended. The Court rejected DLS-AU's argument that Bernardo's claim was time-barred, applying the
doctrine of estoppel due to the university’s continued employment of Bernardo past the retirement age.
The Court thus affirmed the lower courts' rulings, granting Bernardo his retirement benefits.