Part-Time Employees Deserve Retirement Benefits: A Clear Message from the Philippine Supreme Court

Father Saturnino Urios University, Inc., et al. v. Atty. Ruben B. Curaza, G.R. No. 223621, June 10, 2020

Imagine dedicating decades to teaching, shaping young minds, yet being denied the retirement benefits you rightfully earned because you were classified as a part-time employee. This was the reality for Atty. Ruben B. Curaza until the Philippine Supreme Court intervened, setting a precedent that could change the lives of countless part-time workers across the nation.

In the case of Father Saturnino Urios University, Inc., et al. v. Atty. Ruben B. Curaza, the Supreme Court addressed a critical issue: whether part-time employees are entitled to retirement benefits under Republic Act No. 7641, the Retirement Pay Law. Atty. Curaza, a part-time professor at Father Saturnino Urios University (FSUU), sought retirement benefits after serving for nearly three decades. The university argued that as a part-time employee, he was not eligible. The Court’s decision not only clarified the law but also underscored the importance of recognizing the contributions of all employees, regardless of their employment status.

Understanding the Legal Landscape

Republic Act No. 7641, enacted to ensure that employees receive retirement benefits upon reaching the age of 60 and having served at least five years, is a cornerstone of Philippine labor law. The law aims to reward employees for their dedication and service. However, the question of whether part-time employees fall under its purview had been a contentious issue.

The Supreme Court’s decision hinges on the interpretation of the law’s coverage. The relevant section states, “Any employee may be retired upon reaching the retirement age…” and specifies that employees who have served at least five years are entitled to retirement benefits. Importantly, the law does not explicitly exclude part-time employees.

The Implementing Rules of the Labor Code further clarify that the 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,” except for specific exemptions. These exemptions include employees of the National Government and its subdivisions, and those of small retail, service, and agricultural establishments.

A Labor Advisory issued in 1996 by then Secretary of Labor Leonardo A. Quisumbing explicitly includes part-time employees among those covered by the law. This advisory, coupled with the broad language of the statute, forms the legal foundation for the Court’s ruling.

The Journey to Justice: Atty. Curaza’s Case

Atty. Ruben B. Curaza began his teaching career at FSUU in 1979, initially as a part-time instructor in commercial law. Over the years, he expanded his role, teaching in various departments and even becoming a pioneering professor in the College of Law. Despite his long service, when he applied for early retirement in 2008, FSUU denied his request, citing his part-time status.

Undeterred, Atty. Curaza filed a complaint with the National Labor Relations Commission (NLRC) in 2010, seeking retirement benefits, damages, and attorney’s fees. The university argued that Atty. Curaza was not a permanent employee and therefore not entitled to benefits under Republic Act No. 7641.

The Executive Labor Arbiter ruled in favor of Atty. Curaza, stating that the law applies to part-time employees and that his 24 years of service qualified him for retirement benefits. On appeal, the NLRC affirmed this decision.

The case eventually reached the Court of Appeals, which upheld the NLRC’s ruling but modified the computation of Atty. Curaza’s service to 22 years based on his teaching load records. The university and the Catholic Educational Association of the Philippines, as intervenor, sought a review by the Supreme Court, arguing that part-time employees cannot attain regular permanent status and thus should not receive retirement benefits.

The Supreme Court, however, rejected these arguments. In its decision, the Court emphasized that Republic Act No. 7641 does not distinguish between permanent and non-permanent employees. The Court stated, “The text of the law as passed nonetheless makes no distinction between permanent and non-permanent employees. Thus, the exclusion of non-permanent employees from the coverage of Republic Act No. 7641 has no legal basis.”

Furthermore, the Court upheld the Court of Appeals’ computation of Atty. Curaza’s service, affirming that he was entitled to retirement benefits for 22 years of service.

Impact and Practical Advice

The Supreme Court’s ruling in this case sets a significant precedent for part-time employees across the Philippines. It affirms that part-time workers are entitled to retirement benefits under Republic Act No. 7641, provided they meet the age and service requirements.

For businesses and educational institutions, this decision means reviewing and potentially revising employment policies to ensure compliance with the law. Employers must recognize that part-time employees contribute significantly to their operations and should be treated fairly in terms of retirement benefits.

Individuals working part-time should be aware of their rights under the law. If you believe you are eligible for retirement benefits, it is crucial to document your service carefully and, if necessary, seek legal advice to enforce your rights.

Key Lessons:

• Part-time employees are entitled to retirement benefits under Republic Act No. 7641 if they meet the age and service requirements.
• Employers must ensure their retirement policies comply with the law and do not discriminate against part-time workers.
• Employees should keep detailed records of their service to support claims for retirement benefits.

Frequently Asked Questions

Who is covered by Republic Act No. 7641?

All employees in the private sector, regardless of their employment status, are covered by the law, except for specific exemptions such as government employees and those of small establishments.

How many years of service are required to qualify for retirement benefits?

An employee must have served at least five years to be eligible for retirement benefits under Republic Act No. 7641.

Can part-time employees claim retirement benefits if they have worked for multiple employers?

Yes, as long as the total service across all employers meets the five-year requirement, part-time employees can claim retirement benefits.

What should I do if my employer denies me retirement benefits?

You should gather evidence of your service and consider filing a complaint with the National Labor Relations Commission or seeking legal advice.

How is the length of service calculated for part-time employees?

The length of service is typically calculated based on the actual time worked, as evidenced by employment records and payroll documents.

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