G.R. No. 97468-70 September 2, 1993
SOUTHEAST ASIAN FISHERIES DEVELOPMENT CENTER represented by its Chief, DR. FLOR J. LACANILAO, petitioner, vs. DANILO ACOSTA in his capacity as Labor Arbiter of the National Labor Relations Commission, Regional Arbitration, Branch VI, CORAZON CANTO, DAN BALIAO, ELIZABETH SUPETRAN, CARMELITA FERRER, CATHRYN CONTRADOR, and DORIC VELOSO, respondents.
FACTS
Private respondents filed two labor cases (RAB Case No. VI-0156-86 and RAB Case No. VI-0214-86) against petitioner Southeast Asian Fisheries Development Center (SEAFDEC) before the National Labor Relations Commission (NLRC), Regional Arbitration Branch in Iloilo City, claiming wrongful termination from employment. Petitioner SEAFDEC, contending it is an international inter-government organization, filed a Motion to Dismiss challenging the labor arbiter’s jurisdiction. The labor arbiter denied the motion on September 20, 1990, and a subsequent Motion for Reconsideration was denied on January 7, 1991. Petitioner then filed an original petition for certiorari and prohibition with this Court, which initially dismissed the petition on March 30, 1992, but later reconsidered upon petitioner’s motion.
ISSUE
Whether the labor arbiter has jurisdiction over the labor cases filed against SEAFDEC, an international inter-governmental organization.
RULING
The labor arbiter has no jurisdiction over the labor cases. Petitioner SEAFDEC is an international agency enjoying diplomatic immunity from suit. It was established by an agreement among several Southeast Asian governments, including the Republic of the Philippines. As an intergovernmental organization with autonomous and non-political purposes, it possesses a distinct international juridical personality independent of the municipal law of the host state, and is thus immune from local jurisdiction, including that of the NLRC. The immunity is functional to prevent host government interference and to ensure impartial operation. The Republic of the Philippines, as a signatory, agreed to the terms of the establishing agreement, and Presidential Decree No. 292 affirmed the autonomous character of SEAFDEC. Furthermore, petitioner timely raised the issue of jurisdiction before resting its case and before the termination of the proceedings, and thus did not waive its immunity. The Court granted the petition, set aside the labor arbiter’s order, and enjoined further proceedings in the labor cases.
