GR 157141; (August, 2005) (Digest)
G.R. No. 157141 . August 31, 2005. SPS. RODRIGO LACIERDA and DR. ERLINDA CRUZ-LACIERDA, et al., Petitioners, vs. DR. ROLANDO PLATON, AGNES LACUESTA, et al., Respondents.
FACTS
Petitioners were employees of the Southeast Asian Fisheries Development Center (SEAFDEC), an international organization enjoying immunity from suit. They were assigned to a training program funded by the Japan International Cooperation Agency (JICA) under a Memorandum of Agreement (MOA) with SEAFDEC. Petitioners received cash advances for program-related travel. An internal audit alleged discrepancies in their liquidation reports, specifically that submitted hotel receipts were higher than actual payments. Consequently, SEAFDEC management, through respondents, charged petitioners administratively for misrepresentation and fraudulent machination. Petitioners waived a formal hearing. Subsequently, respondent Platon terminated their employment.
More than a year later, petitioners filed a complaint for “Interference with Contract, Specific Performance and Damages” against the individual respondents in the Regional Trial Court (RTC). They alleged the suit was not against SEAFDEC but against the officers in their personal capacities for malicious and oppressive acts. Their primary prayer sought reinstatement to their positions at SEAFDEC with back salaries and benefits. The RTC dismissed the complaint for lack of jurisdiction, ruling it was essentially a labor dispute and a suit against SEAFDEC, which is immune. Petitioners’ motion for reconsideration was denied.
ISSUE
Whether the Regional Trial Court correctly dismissed the complaint for lack of jurisdiction.
RULING
Yes, the Supreme Court affirmed the RTC’s dismissal. The Court held that the complaint, despite being artfully couched as a tort action for interference with contractual relations against individuals, was in reality an action questioning the legality of petitioners’ dismissal from SEAFDEC. The core relief sought—reinstatement with back wages and benefits—is a remedy exclusively within the realm of labor relations. This primary prayer betrayed the true nature of the suit as a labor dispute, which falls under the original and exclusive jurisdiction of the Labor Arbiters under the Labor Code, not the regular courts.
Furthermore, the Court found that the suit was, in substance, a suit against SEAFDEC. Since SEAFDEC is an international organization clothed with diplomatic immunity, it cannot be sued without its consent. The acts complained of—the audit, the administrative charges, the investigation, and the termination—were all carried out by the respondents in their official capacities as officers implementing SEAFDEC’s internal rules. A suit against its officers for acts done in their official capacity is deemed a suit against the institution itself. The allegation of individual tortious acts was a mere conclusion of law intended to circumvent SEAFDEC’s immunity. Therefore, the RTC correctly declined jurisdiction.