SEAFDEC v. Acosta & NLRC are autonomous and beyond the control of any one State.

are autonomous and beyond the control of any one State. They have a juridical
Immunity | September 2, 1993 | Vitug, J.
SEAFDEC = South East Asian Fisheries Development Center
SUMMARY: Two labor cases were filed against SEAFDEC for illegal dismissal. The
Court ruled that public respondent NLRC has no jurisdiction over the case because of
SEAFDEC’s immunity as an international agency.
DOCTRINE: 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.
FACTS:
 Two labor cases were filed by the herein private respondents against petitioner
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.
 SEAFDEC-AQD is a department of an international organization, the Southeast Asian
Fisheries Development Center, organized through an agreement in 1967 by the
governments of Malaysia, Singapore, Thailand, Vietnam, Indonesia and the
Philippines with Japan as the sponsoring country.
 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.
personality independent of the municipal law of the State they are situated.
 Permanent international commissions and administrative bodies have been created by
the agreement of a considerable number of States for a variety of international
purposes, economic or social and mainly non-political. In so far as they are
autonomous and beyond the control of any one State, they have a distinct juridical
personality independent of the municipal law of the State where they are situated. As
such, according to one leading authority "they must be deemed to possess a species of
international personality of their own."
 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.
WHEREFORE, our resolution, dated 30 March 1992, dismissing the petition for certiorari, is
hereby reconsidered, and another is entered (a) granting due course to the petition; (b) setting
aside the order, dated 20 September 1990, of the public respondent; and (c) enjoining the public
respondent from further proceeding with RAB Case No. VI-0156-86 and RAB Case No. VI-
0214-86. No costs.

ISSUE: Whether or not the Labor Arbiter lacks jurisdiction over the dispute - NO

RATIO:
 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