G.R. No. 82631 - Southeast Asian Fisheries Development Center vs. National Labor Relations Commission

On June 10, 1983, private respondent Yong Chan Kim filed a complaint for illegal dismissal against petitioner Southeast Asian Fisheries Development Center (SEAFDEC).
On June 16, 1986, the Labor Arbiter rendered a decision ordering SEAFDEC to reinstate Yong to his former position, to pay full back wages, and to grant moral damages amounting to P50,000.00.

SEAFDEC appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC).
Concurrently, respondent Yong filed a partial appeal seeking an increase of the moral damages award to P200,000.00.
On August 20, 1987, the NLRC affirmed the Labor Arbiter’s decision but enhanced the award by:

A motion for reconsideration was filed by SEAFDEC but was denied by the NLRC in its Resolution dated February 15, 1988.

SEAFDEC sought relief by filing a petition for certiorari under Rule 65 of the Revised Rules of Court, challenging the NLRC’s rulings.
On May 9, 1988, SEAFDEC filed an urgent motion for a restraining order to prevent the issuance of a writ of execution in connection with the NLRC’s decision.
On May 12, 1988, the Court issued a temporary restraining order without first giving due course to the petition.
On July 12, 1989, the Court resolved to give due course to the petition by requiring the parties to submit their respective memoranda.

On February 14, 1992, in Southeast Asian Fisheries Development Center - Aquaculture Department v. National Labor Relations Commission, this Court held that the NLRC had no jurisdiction over SEAFDEC, recognizing its status as an international agency beyond the jurisdiction of Philippine courts and local agencies.
Relying on this pronouncement, SEAFDEC filed a supplemental petition on May 16, 1992, raising the issue of lack of jurisdiction of the NLRC in the present case.
Respondent Yong argued against allowing SEAFDEC to raise the jurisdictional issue at this stage, invoking the doctrine of estoppel, as established in Tijam v. Sibonghanoy.

SEAFDEC was established by the Governments of Burma, Cambodia, Indonesia, Japan, Laos, Malaysia, the Philippines, Singapore, Thailand, and Vietnam in pursuit of mutual cooperation for the development and promotion of fisheries in Southeast Asia.
The status and operational purpose of SEAFDEC are based on the Agreement Establishing the Center, which clearly outlines its role in the regional fisheries development.
Subsequent cases, including Lacanilao v. de Leon and Southeast Asian Fisheries Development Center - Aquaculture Department v. Danilo Acosta, have reaffirmed the diplomatic immunity enjoyed by SEAFDEC.

Respondent Yong contended that SEAFDEC was estopped from raising the issue of lack of jurisdiction since it failed to do so before the lower tribunals.
Yong cited the Tijam doctrine (Tijam v. Sibonghanoy) to support his position, arguing that the late raise of a jurisdictional objection should not be entertained.
The Court, however, clarified that the estoppel doctrine as applied in Tijam is limited to ordinary litigants and does not extend to entities enjoying sovereign or diplomatic immunity.

Whether the NLRC had jurisdiction to decide the case involving an international organization, SEAFDEC, given its recognized immunity from local jurisdiction.
Whether SEAFDEC is estopped from raising the issue of lack of jurisdiction at the appellate level due to its failure to do so before the Labor Arbiter or the NLRC.
Whether the subsequent awards of reinstatement, back wages, moral damages, exemplary damages, and attorney’s fees should be annulled on the ground that the NLRC lacked jurisdiction over an international agency.