Case Digest (G.R. No. 97468-70)
Facts:
Southeast Asian Fisheries Development Center represented by its Chief, Dr. Flor J. Lacanilao v. 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, G.R. No. 97468-70, September 02, 1993, the Supreme Court Third Division, Vitug, J., writing for the Court.Private respondents (individual former employees) filed two labor complaints—RAB Case No. VI-0156-86 and RAB Case No. VI-0214-86—before the NLRC Regional Arbitration Branch in Iloilo, alleging wrongful dismissal by petitioner SEAFDEC. On 22 August 1990, SEAFDEC moved to dismiss for lack of jurisdiction, asserting that it is an international inter-governmental organization immune from local jurisdiction. The Labor Arbiter (respondent Acosta) denied the Motion to Dismiss in an order dated 20 September 1990; a motion for reconsideration was likewise denied on 07 January 1991.
SEAFDEC filed an original petition for certiorari and prohibition with this Court, praying also for a temporary restraining order to enjoin further proceedings; the Court issued the TRO on 20 March 1991. The Solicitor General filed a manifestation and was excused from commenting for the labor arbiter. On 30 March 1992, the Court originally dismissed SEAFDEC’s petition for failure to sufficiently show grave abuse of discretion by the labor arbiter and lifted the TRO. SEAFDEC moved for reconsideration of that dismissal, reiterating that the labor arbiter l...(Pro-only)
Issues:
- Was SEAFDEC’s raising of lack of jurisdiction timely such that it did not impliedly waive immunity from suit?
- Does SEAFDEC, as constituted and by virtue of the enabling instruments and Presidential Decree No. 292, enjoy immunity from the jurisdiction of Philippine labor tribunals so as to bar NLRC proceedings in RAB Case Nos. ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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