G.R. No. 97468-70 - Southeast Asian Fisheries Development Center vs. Acosta

The petitioner is the Southeast Asian Fisheries Development Center (SEAFDEC), represented by its Chief, Dr. Flor J. Lacanilao.
The respondents include:

Danilo Acosta in his capacity as Labor Arbiter of the National Labor Relations Commission (NLRC), Regional Arbitration, Branch VI.
Private respondents – including Corazon Canto, Dan Baliao, Elizabeth Supetran, Carmelita Ferrer, Cathryn Contrador, and Doric Veloso – who had filed labor cases.

Two labor cases (RAB Case No. VI-0156-86 and RAB Case No. VI-0214-86) were initiated by the private respondents against SEAFDEC, alleging wrongful termination.

On 22 August 1990, SEAFDEC, asserting its status as an international intergovernmental organization, filed a Motion to Dismiss.

The motion challenged the jurisdiction of the local labor arbiter over the dispute.

On 20 September 1990, the Labor Arbiter issued an order denying the Motion to Dismiss.
A Motion for Reconsideration was subsequently filed.

On 20 March 1991, the Court granted a Temporary Restraining Order (TRO) as prayed for by SEAFDEC.
On 30 March 1992, the Court dismissed the original petition for certiorari, noting that the petitioner had failed to demonstrate grave abuse of discretion on the part of the Labor Arbiter.
SEAFDEC later moved for reconsideration on the basis that the issue of jurisdiction – and consequently its immunity as an international organization – was not properly addressed by the Labor Arbiter.

SEAFDEC claimed its status as an international intergovernmental organization and hence argued it was immune from the jurisdiction of local courts.
The petitioner referenced its earlier establishment by the governments of several Southeast Asian countries and cited its participation in agreements (such as the Agreement establishing SEAFDEC) to underscore its immunity.
The case materials include references to precedents and legal opinions supporting the view that international organizations, due to their non-political, autonomous nature, possess immunity from local jurisdiction.
The petitioner timely raised the issue of jurisdiction, contesting that it had not waived its immunity, contrary to the respondents’ contentions.

Whether SEAFDEC, as an international intergovernmental organization, is immune from the jurisdiction of the Philippine labor arbiter and local courts.

Does the nature of SEAFDEC and its enabling instruments (such as the Agreement establishing SEAFDEC) grant it diplomatic and jurisdictional immunity?
Was there an implied or express waiver of immunity by SEAFDEC, particularly in relation to the labor disputes?

Whether the Labor Arbiter erred in denying SEAFDEC’s Motion to Dismiss on the grounds of lack of jurisdiction.
Whether the petition for certiorari and the subsequent temporary restraining order should be granted in light of SEAFDEC’s international immunity.