Case Summary (G.R. No. 82631)
Procedural History
The case originates from a complaint filed by respondent Yong Chan Kim against petitioner SEAFDEC, alleging illegal dismissal. The Labor Arbiter ruled in favor of Yong, ordering his reinstatement along with the payment of back wages and moral damages. Subsequent appeals by both parties resulted in the NLRC affirming the Labor Arbiter's decision but increasing the awarded damages and fees. Petitioner subsequently challenged the NLRC's rulings in the Supreme Court through a petition for certiorari under Rule 65.
Jurisdictional Challenges
The core issue raised by SEAFDEC was the jurisdiction of the NLRC over the organization, which is characterized as an international agency established by multiple Southeast Asian countries, including the Philippines. The Supreme Court had previously held in a related case that the NLRC lacked jurisdiction over SEAFDEC due to its international status and the consequent diplomatic immunity enjoyed by such organizations. SEAFDEC argued that the NLRC's decisions infringed upon its operational independence as an international entity.
Estoppel Argument
Yong responded to the jurisdictional challenge by invoking the principle of estoppel, arguing that SEAFDEC was barred from raising this issue since it did not do so in earlier proceedings. He cited the Tijam v. Sibonghanoy case, which allowed for exceptions to the general rule against the waiver of jurisdictional objections. However, the Supreme Court clarified that estoppel cannot confer jurisdiction upon a tribunal that lacks it, reiterating its previously established position regarding the unsuitability of this principle in cases involving entities with diplomatic immunity.
Rulings on Immunity
The Supreme Court emphasized that SEAFDEC, as an international organization established for fisheries development, enjoyed jurisdictional immunity from local courts. This immunity aims to prevent interference by the national government in the operations and policies of international organizations, thereby ensuring th
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Case Background
- The case arises from a petition for certiorari under Rule 65 of the Revised Rules of Court.
- The petitioner, Southeast Asian Fisheries Development Center (SEAFDEC), seeks to reverse the decisions made by the National Labor Relations Commission (NLRC) dated August 20, 1987, and February 15, 1988, pertaining to RAB Case No. 0093-83.
- A complaint for illegal dismissal was filed by private respondent Yong Chan Kim against SEAFDEC on June 10, 1983.
Labor Arbiter's Decision
- On June 16, 1986, the Labor Arbiter issued a decision ordering SEAFDEC to reinstate Yong to his former position and to pay full back wages.
- The Labor Arbiter also awarded Yong moral damages amounting to P50,000.00.
Appeals and NLRC Ruling
- SEAFDEC appealed the Labor Arbiter's decision, while Yong filed a partial appeal to increase the moral damages awarded to him.
- On August 20, 1987, the NLRC affirmed the Labor Arbiter’s decision but increased the moral damages to P200,000.00, awarded an additional P50,000.00 in exemplary damages, and granted ten percent of the total monetary awards as attorney's fees.
Motion for Reconsideration
- SEAFDEC's motion for reconsideration was denied by the NLRC in a resolution dated February 15, 1988.
- This denial prompted SEAFDEC to file a petition fo