SEAFDEC v. Acosta

SEAFDEC v. Acosta G.R. 97468-70 Sept. 2, 1993 Facts: Two labor cases were filed by the herein private respondents against petitioner, Southeast Asian Fisheries Development Center (SEAFDEC), before the NLRC of Iloilo City. In these cases, the private respondents Canto, Baliao, Supetran, Ferrer, Contrador and Veloso claim that they have been wrongfully terminated from their employment by the petitioner. Petitioner contends to be an international inter-government organization composed of various Southeast Asian countries. They filed a motion to dismiss challenging the jurisdiction of the public respondent in taking cognizance of the above cases. Labor arbiter Acosta, herein private respondent, issued an order denying the motion to dismiss. A motion for reconsideration was subsequently filed but it was likewise denied. The court then issued a temporary restraining order which sets aside the order of respondent Labor arbiter. Private respondents allege that petitioner is not immune from suit and assuming that it is indeed an international organization, it has impliedly waived its immunity by belatedly raising the issue of jurisdiction. The instant petition was dismissed along with the lifting of the issued TRO. Issue: Whether or not the Labor Arbiter lacks jurisdiction over the dispute. Ruling: SEAFDEC is an international agency enjoying diplomatic immunity and beyond the jurisdiction of the NLRC. It was established to contribute to the promotion of the fisheries development in Southeast Asia by mutual cooperation among the member governments of the Center. Being an intergovernmental organization, SEAFDEC enjoys functional independence and freedom from control of the state in whose territory its office is located. Insofar as international commissions are concerned, they are autonomous and beyond the control of any one State. They have a juridical personality independent of the municipal law of the State they are situated. One of the basic immunities of an international organization is immunity from local jurisdiction. The reason for this is that the subjection of such an organization to the authority of the local courts would afford a convenient medium thru which the host government may interfere in their operations or even influence or control its policies and decisions of the organization. Besides, such objection to local jurisdiction would impair the capacity of such body to discharge its responsibilities impartially on behalf of its member-states.

Anent the issue of waiver of immunity, the petitioner has timely raised the issue of jurisdiction since it has done so before it rested its case and before the proceedings had been terminated. Hence, the petition is granted due course. The order denying the motion to dismiss is set aside.