Case Digest (G.R. No. 82631)
Facts:
Southeast Asian Fisheries Development Center v. National Labor Relations Commission and Yong Chan Kim, G.R. No. 82631, February 23, 1995, Supreme Court First Division, Quiason, J., writing for the Court. This is a petition for certiorari under Rule 65 of the Revised Rules of Court seeking to annul the NLRC Decision (Aug. 20, 1987) and Resolution (Feb. 15, 1988) in RAB Case No. 0093-83.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 ordered SEAFDEC to reinstate Yong to his former position with full back wages and awarded P50,000 as moral damages. Both parties appealed: SEAFDEC appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC), while Yong filed a partial appeal seeking an increase of moral damages to P200,000.
On August 20, 1987, the NLRC affirmed the Labor Arbiter’s decision but increased moral damages to P200,000, added exemplary damages of P50,000, and awarded ten percent of the total monetary awards as attorney’s fees. The NLRC denied reconsideration on February 15, 1988. SEAFDEC filed a petition for review on certiorari with the Supreme Court and, on May 9, 1988, moved for an order restraining the NLRC from issuing a writ of execution; the Court issued a temporary restraining order on May 12, 1988 without giving the petition due course. The Court later gave due course to the petition on July 12, 1989 and required memoranda.
While the petition was pending, this Court on February 14, 1992 decided Southeast Asian Fisheries Development Center - Aquaculture Department v. National Labor Relations Commission, 206 SCRA 283 (1992), holding that the NLRC lacked jurisdiction over SEAFDEC because SEAFDEC is an international agency beyond local courts’ jurisdiction. Relying on that decision, SEAFDEC filed a supplemental petition on May 16, 1992 asserting lack of NLRC jurisdiction. Yong opposed, arguing SEAFDEC was estopped from raising jurisdictional objection because it failed to do so earlier, invoking the Tijam v. Sibonghanoy doctrine.
The parties also placed in the record background on SEAFDEC’s status as an international organization established by several governments (including the Philippines) and prior jurisprudence recognizing its diplomatic immunity (see Lacanilao v. de Leon, 147 SCRA 286 (1987); Southeast...(Pro-only)
Issues:
- Does the NLRC have jurisdiction to entertain and decide an illegal dismissal complaint filed against SEAFDEC, an international organization?
- Was SEAFDEC estopped from raising the objection of lack of jurisdiction before the NLRC and the Labor Arbiter due to its fa...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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