Case Summary (G.R. No. 86773)
Establishment and Nature of SEAFDEC-AQD
SEAFDEC-AQD is a department of an international organization established through an agreement signed on December 28, 1967, by member governments of Southeast Asia, including the Philippines, and sponsored by Japan. It was created to promote fisheries development through mutual cooperation among member states. The Aquaculture Department was organized in 1973 in Iloilo to focus on aquaculture research. As an international organization, SEAFDEC-AQD enjoys functional independence and is not subject to local state control.
Employment and Termination of Juvenal Lazaga
Juvenal Lazaga was employed by SEAFDEC-AQD first as a probationary Research Associate in 1975 and subsequently promoted to Senior External Affairs Officer and Professional III with leadership of the External Affairs Office. On May 8, 1986, petitioner Lacanilao, as Chief, notified Lazaga of his termination due to financial constraints, assuring him separation benefits based on his length of service. Lazaga's claim for unpaid separation benefits resulted in filing a complaint before the NLRC.
Proceedings Before the National Labor Relations Commission
Lazaga filed a complaint for non-payment of separation pay, moral damages, and attorney’s fees. Petitioners countered, challenging the NLRC’s jurisdiction on the ground that SEAFDEC-AQD’s status as an international organization granted it immunity from local jurisdiction. They also raised Lazaga’s alleged outstanding accountability for property and non-fulfillment of clearance requirements. The labor arbiter ruled in favor of Lazaga, ordering payment of separation benefits amounting to ₱126,458.89 plus interest, damages, and attorney’s fees. The NLRC affirmed the award except for damages and attorney’s fees, which it deemed unsupported.
Jurisdictional Immunity of SEAFDEC-AQD
SEAFDEC-AQD’s status as an international agency grants it immunity from local jurisdiction under principles of international law. The Agreement Establishing SEAFDEC, to which the Philippines is a signatory, stipulates that the national laws of member states apply only in limited respects related to contributions made to the organization. The organization’s governance lies with its Council, vesting SEAFDEC with functional autonomy immune from interference by the host country’s judiciary or administrative agencies. This immunity aims to preserve impartiality and independence from local political influence or legal processes, especially in management and operational decisions.
Legal Basis for Immunity and Jurisdictional Issues
Precedents and scholarly authorities recognize international organizations as possessing distinct juridical personality, granting them immunity from local legal processes. The Philippine Department of Justice previously opined that SEAFDEC’s immunity bars local courts and tribunals, such as the NLRC, from asserting jurisdiction, as this could result in unwanted interference. Jurisdiction is a matter of law and cannot be conferred by consent or estoppel. The petitioners argued that the NLRC lacked jurisdiction ab initio, rendering its decisions void.
Rejection
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Case Background and Parties Involved
- Petitioners comprise the Southeast Asian Fisheries Development Center-Aquaculture Department (SEAFDEC-AQD) and several officials: Dr. Flor Lacanilao (Chief), Rufil Cuevas (Head, Administrative Division), and Ben de los Reyes (Finance Officer).
- Respondents include the National Labor Relations Commission (NLRC) and Juvenal Lazaga, the private respondent.
- The dispute centers on the non-payment of separation benefits and post-employment benefits to Juvenal Lazaga following his termination by SEAFDEC-AQD.
- Lazaga was employed initially as a Research Associate on probation in 1975 and later promoted to Senior External Affairs Officer and Head of External Affairs Office, earning monthly basic salary and allowances.
Facts of the Case
- SEAFDEC-AQD is an international organization established under an agreement involving multiple Southeast Asian governments and Japan, the sponsoring country.
- Lazaga's employment was terminated on May 15, 1986, due to financial constraints communicated via notice by petitioner Lacanilao.
- Lazaga claimed entitlement to separation pay equivalent to one month’s salary per year of service plus other benefits.
- Petitioners failed to pay separation benefits, prompting Lazaga to file a complaint before the NLRC for non-payment including claims for moral damages and attorney’s fees.
- Petitioners contended the NLRC lacked jurisdiction as SEAFDEC-AQD is an international organization and alleged Lazaga had outstanding property accountability issues.
- Lazaga countered alleging the withholding of clearances was bad faith and politically motivated.
- The labor arbiter ordered payment of separation and post-employment benefits with interest and some damages as relief.
- The NLRC affirmed the decision partially but removed actual damages and attorney's fees for lack of basis.
- Petitioners’ motion for reconsideration was denied, leading to the present petition for certiorari.