Case Summary (G.R. No. 97468-70)
Applicable Law and Jurisdictional Issue
The petitioner submitted a Motion to Dismiss on the grounds that it is an international inter-governmental organization, thus asserting that the NLRC lacked jurisdiction over the cases filed against it. The public respondent denied this motion in its order dated September 20, 1990, prompting SEAFDEC to file a petition for certiorari and prohibition before the Supreme Court, which included a request for a temporary restraining order against the labor arbiter’s order.
Court's Preliminary Action and Argumentation
On March 20, 1991, the Supreme Court granted the request for a temporary restraining order. The private respondents and the labor arbiter contended that SEAFDEC should not be granted immunity from suit, arguing that the petitioner had waived this immunity by raising the jurisdictional issue late in the proceedings. In contrast, the Solicitor General moved to be excused from filing comments due to disagreement with the labor arbiter's position.
Dismissal and Reconsideration
On March 30, 1992, the Supreme Court dismissed the petition, concluding that SEAFDEC failed to demonstrate a clear case of grave abuse of discretion by the labor arbiter. Following this dismissal, SEAFDEC filed a motion for reconsideration, reiterating its argument regarding the lack of jurisdiction of the labor arbiter over disputes involving it as an international organization.
Ruling on International Immunity
The Supreme Court ultimately ruled in favor of SEAFDEC, reaffirming its status as an international agency entitled to diplomatic immunity. Citing previous decisions, the Court emphasized that SEAFDEC, as an intergovernmental organization established by multiple Southeast Asian countries, possesses functional independence and is not under the jurisdiction of Philippine courts. The rationale for such immunity was grounded in the recognition of the need to maintain the impartiality and operational integrity of international organizations.
Conclusion and Final Decision
The Supreme Court's resolution granted reconsideration of the previous dismissal, reasserting that SEAFDEC is immune to local jurisdiction. The Court set aside the labor arbiter’s September 20, 1990 order and enjoined further proceedings in the cases against SEAFDEC. C
...continue readingCase Syllabus (G.R. No. 97468-70)
Case Overview
- The case at hand is an original petition for certiorari and prohibition filed by the Southeast Asian Fisheries Development Center (SEAFDEC), represented by its Chief, Dr. Flor J. Lacanilao.
- The petition seeks to set aside the order dated September 20, 1990, issued by respondent labor arbiter Danilo Acosta, which denied SEAFDEC's motion to dismiss for lack of jurisdiction.
- Two labor cases, RAB Case No. VI-0156-86 and RAB Case No. VI-0214-86, were filed by private respondents against SEAFDEC, alleging wrongful termination from their employment.
Jurisdictional Dispute
- On August 22, 1990, SEAFDEC filed a Motion to Dismiss, asserting its status as an international inter-government organization and contesting the jurisdiction of the National Labor Relations Commission (NLRC).
- The labor arbiter issued an order denying the motion on September 20, 1990, leading to SEAFDEC's petition for certiorari.
- A subsequent motion for reconsideration was denied on January 7, 1991.
Temporary Restraining Order
- The Supreme Court issued a temporary restraining order on March 20, 1991, in response to SEAFDEC's petition.
- The private respondents and the labor arbiter contended that SEAFDEC is not immune from suit, and that it had implicitly waived its