GR 86773; (February, 1992) (Digest)
G.R. No. 86773 . February 14, 1992.
SOUTHEAST ASIAN FISHERIES DEVELOPMENT CENTER-AQUACULTURE DEPARTMENT (SEAFDEC-AQD), DR. FLOR LACANILAO, RUFIL CUEVAS, BEN DELOS REYES, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and JUVENAL LAZAGA, respondents.
FACTS
Petitioner SEAFDEC-AQD is a department of the Southeast Asian Fisheries Development Center, an international organization established by an agreement entered into by several governments, including the Philippines. Private respondent Juvenal Lazaga was employed by SEAFDEC-AQD. On May 8, 1986, he received a notice of termination from petitioner Dr. Flor Lacanilao, citing financial constraints and informing him of his entitlement to separation benefits. SEAFDEC-AQD failed to pay these benefits.
Lazaga filed a complaint for non-payment of separation benefits before the National Labor Relations Commission (NLRC). Petitioners, in their answer, argued that the NLRC had no jurisdiction over SEAFDEC-AQD as it is an international organization immune from suit. They also contended that Lazaga had not secured required clearances for property accountability. The labor arbiter ruled in favor of Lazaga, ordering payment of separation pay and benefits. The NLRC affirmed the decision on the monetary award but deleted the damages.
ISSUE
Whether or not the National Labor Relations Commission has jurisdiction over SEAFDEC-AQD, an international organization, in a labor dispute filed by a former employee.
RULING
The Supreme Court ruled that the NLRC has no jurisdiction over SEAFDEC-AQD. The legal logic is anchored on the principle of sovereign immunity extended to international organizations. SEAFDEC was established by an international agreement among several sovereign states, including the Philippines. As an intergovernmental organization, it enjoys functional independence and immunity from the domestic legal processes of the host state to ensure the free and unimpeded performance of its functions. This immunity from suit is necessary for it to operate effectively without interference from local authorities.
The Court clarified that jurisdiction is conferred by law and cannot be waived or conferred by the parties’ agreement or by estoppel. The fact that SEAFDEC-AQD operated within the Philippines and terminated an employee does not subject it to the jurisdiction of local labor tribunals. The Court distinguished this case from Lacanilao v. De Leon, noting that in that prior case, the controversy was between two claimants to a position, not a suit against the international organization itself where immunity was properly invoked. Consequently, the NLRC’s decision was rendered without jurisdiction and is null and void. The petition was granted, and the NLRC’s decision and resolution were reversed and set aside.