1. Case: G.R. No.

85750 (International Catholic Migration Commission Case)

Facts:

After the Vietnam War, Vietnamese refugees were fleeing from South Vietnam's communist rule.

An Agreement was made between the Philippine Government and the United Nations High
Commissioner for Refugees to establish a refugee processing center in Bataan.

The International Catholic Migration Commission (ICMC) was accredited by the Philippine Government
to operate the refugee processing center.

ICMC is an international organization registered with the United Nations, involved in humanitarian work.

Trade Unions of the Philippines and Allied Services (TUPAS) filed a Petition for Certification Election
among ICMC's rank and file members.

ICMC opposed the petition, claiming diplomatic immunity.

Med-Arbiter sustained ICMC's claim of immunity, but Director Pura Calleja of the Bureau of Labor
Relations (BLR) reversed the decision.

The Philippine Government later granted ICMC the status of a specialized agency with diplomatic
privileges and immunities.

ICMC sought dismissal of the TUPAS petition based on its immunity, but BLR Director persisted in
ordering a certification election.

ICMC filed a Petition for Certiorari with Preliminary Injunction to challenge the BLR's order.

Issue:

Whether the grant of diplomatic privileges and immunities to ICMC extends to immunity from the
application of Philippine labor laws.

Ruling:

The Court granted ICMC's petition, set aside the BLR's order for certification election, and made the
Temporary Restraining Order permanent.

The Court found that ICMC's immunity from local jurisdiction was necessary to avoid interference by the
host country in its internal workings and to ensure unhampered performance of its functions.

While ICMC employees have recourse for dispute settlement, including provisions for disputes arising
from contracts, the grant of immunity still applies to protect the organization from political pressure or
control.

The Court clarified that a certification election could trigger a series of events in the collective bargaining
process, involving ICMC in legal processes that it should be shielded from to maintain its function.
The Court also noted that ICMC's past case (G.R. No. 72222) occurred before it was granted specialized
agency status and immunity.

In summary, the Court upheld ICMC's immunity from local labor laws while recognizing the rights of its
employees to dispute settlement mechanisms.

Case: G.R. No. 89331 (International Rice Research Institute Case)

Facts:

The International Rice Research Institute (IRRI) was established in the Philippines as an autonomous, tax-
free, non-profit, non-stock organization.

IRRI was initially organized as a private corporation subject to local laws but was later granted the status
and immunities of an international organization by Presidential Decree No. 1620.

The Organized Labor Association in Line Industries and Agriculture (OLALIA) filed a Petition for Direct
Certification Election among IRRI's employees.

IRRI opposed the petition, invoking its immunity from Philippine laws.

Med-Arbiter upheld IRRI's immunity, but BLR Director set aside the decision and ordered a certification
election.

The Secretary of Labor later dismissed the petition based on the grant of specialized agency status to
IRRI.

Issue:

Whether IRRI's immunity under Presidential Decree No. 1620 deprives its employees of their right to
self-organization and collective bargaining as guaranteed by the 1987 Constitution.

Ruling:

The Court dismissed Kapisanan's petition, finding no grave abuse of discretion by the Secretary of Labor
and Employment in dismissing the petition for certification election.

IRRI's immunity from local jurisdiction does not deprive its employees of their rights. A forum for
management-employee relations existed, indicating that employees could still organize and cooperate.

The Court noted that the decision of the BLR Director had not become final when Rep. Act No. 6715,
providing for direct appeals to the Secretary of Labor in certification election cases, took effect.

In summary, the Court upheld IRRI's immunity and recognized the rights of its employees to organize and
engage in labor relations.
General Findings in Both Cases:

Diplomatic immunity was granted to both ICMC and IRRI.

International organizations and specialized agencies enjoy immunities to protect them from interference
and to ensure their unhampered function.

The grant of immunity does not deprive employees of dispute settlement mechanisms, and they can still
seek recourse.

The courts accept the executive branch's determination of diplomatic immunity to avoid interfering with
foreign relations.

Immunity covers the organization, its property, and its assets, in both personal and property-related
proceedings.

The Court rectified previously antagonistic positions between government departments to avoid
international embarrassment.

The Court clarified that immunity does not extend to all legal processes, as some legal proceedings may
be necessary for the organization's proper functioning.

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explain further the ruling of supreme court

ChatGPT

In both G.R. No. 85750 (the International Catholic Migration Commission or ICMC case) and G.R. No.
89331 (the International Rice Research Institute or IRRI case), the Supreme Court ruled on the issue of
whether the grant of diplomatic privileges and immunities to these international organizations extends
to immunity from the application of Philippine labor laws. The key findings and explanations from the
rulings can be summarized as follows:

Ruling in G.R. No. 85750 (ICMC Case):

The Court granted ICMC's petition, setting aside the Bureau of Labor Relations' (BLR) order for a
certification election.
The Court acknowledged that ICMC had been granted diplomatic immunity by the Philippine
Government. The primary purpose of this immunity is to protect international organizations from
interference by the host country and to ensure their unhampered ability to carry out their functions.

The Court clarified that while ICMC's employees have recourse for dispute settlement, the grant of
immunity aims to protect the organization from political pressure or control by the host country. The
immunity covers not only legal processes but also any interference by the host country in the
organization's internal workings.

The Court recognized that a certification election could initiate a series of events in the collective
bargaining process, eventually involving ICMC in legal proceedings, which it should be shielded from to
maintain its function.

The Court emphasized that the previous case involving ICMC (G.R. No. 72222) occurred before it was
granted specialized agency status and immunity. Furthermore, ICMC had not invoked its immunity in that
case, and the Court held that, had it done so, it might have been deemed to have waived it.

Ruling in G.R. No. 89331 (IRRI Case):

The Court dismissed Kapisanan's petition, finding no grave abuse of discretion by the Secretary of Labor
and Employment in dismissing the petition for certification election.

The Court recognized that IRRI had been granted immunity through Presidential Decree No. 1620.
However, it emphasized that IRRI's immunity does not deprive its employees of their rights to self-
organization and collective bargaining as guaranteed by the 1987 Constitution.

The Court noted that a forum for management-employee relations had been established, indicating that
employees could still organize and cooperate.

The Court also addressed the procedural issue raised by Kapisanan, explaining that IRRI's case had not
yet become final when Republic Act No. 6715 took effect, providing for direct appeals to the Secretary of
Labor in certification election cases.

In summary, the Supreme Court's rulings in both cases uphold the diplomatic immunity granted to these
international organizations, recognizing the need to protect them from interference while ensuring that
employees still have access to dispute settlement mechanisms and labor rights. The Court also clarified
the procedural aspects of the cases, emphasizing the applicability of relevant laws in determining
jurisdiction and appeals.

2. G.R. No. 113191, September 18, 1996

DEPARTMENT OF FOREIGN AFFAIRS, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, HON.
LABOR ARBITER NIEVES V. DE CASTRO, and JOSE C. MAGNAYI, respondents.
Facts:

On January 27, 1993, private respondent Jose C. Magnayi initiated NLRC-NCR Case No. 00-01-0690-93,
claiming illegal dismissal by the Asian Development Bank (ADB) and violation of labor laws related to
contracting. Two summonses were served, one directly to the ADB and the other through the
Department of Foreign Affairs (DFA), both with a copy of the complaint.

ADB and the DFA notified the Labor Arbiter that ADB, along with its President and Office, enjoyed
diplomatic immunity from legal process, except in cases related to borrowing, guarantees, or the sale of
securities, as per the Charter and the Headquarters Agreement.

The Labor Arbiter ruled in favor of Magnayi, declaring him a regular ADB employee and ordering his
reinstatement, back wages, and other benefits.

The DFA sought the National Labor Relations Commission (NLRC) to vacate the judgment, but the NLRC
Chairman stated that such a request was not within its jurisdiction. The DFA filed a petition for certiorari
with the Supreme Court.

Issue:

Whether the ADB is entitled to diplomatic immunity from legal process.

Whether the DFA has legal standing to file the certiorari petition.

Ruling of the Supreme Court:

The Supreme Court ruled in favor of the ADB and the DFA, holding that ADB was entitled to diplomatic
immunity from legal process. The Court found that the Charter and the Headquarters Agreement
granted the ADB immunity from legal process in most cases, except for specific situations involving
borrowing, guarantees, or the sale of securities.

The Court also affirmed the DFA's legal standing to file the certiorari petition, emphasizing the
importance of the DFA's role in determining who is entitled to diplomatic immunity. The Court held that
certiorari could be entertained in cases where an order or decision is issued in excess of or without
jurisdiction or when it is a patent nullity.

As a result, the Labor Arbiter's decision was declared null and void, and the temporary restraining order
issued by the Supreme Court was made permanent. The Court stressed the significance of respecting
diplomatic immunity as a matter of international law and foreign relations.
 3. G.R. No. L-35131

November 29, 1972

THE WORLD HEALTH ORGANIZATION and DR. LEONCE VERSTUYFT, petitioners, vs. HON. BENJAMIN H.
AQUINO, as Presiding Judge of Branch VIII, Court of First Instance of Rizal, MAJOR WILFREDO CRUZ,
MAJOR ANTONIO G. RELLEVE, and CAPTAIN PEDRO S. NAVARRO of the Constabulary Offshore Action
Center (COSAC), respondents.

Facts:

Dr. Leonce Verstuyft, a petitioner and official of the World Health Organization (WHO), is entitled to
diplomatic immunity, as recognized by the Host Agreement between the Philippine Government and
WHO. On January 10, 1972, his personal effects arrived in the Philippines as unaccompanied baggage
and were allowed free entry from duties and taxes. These effects were stored at the Eternit
Corporation's warehouse. However, on March 3, 1972, at the request of the COSAC officers, respondent
Judge Aquino issued a search warrant for the crates containing these effects, alleging that they contained
highly dutiable goods beyond the official needs of Dr. Verstuyft and that the only way to assess these
items for taxation was through a search warrant. Despite diplomatic immunity recognized by the
executive branch of the Philippine Government, the search warrant was not quashed.

Issue:

The main issue in this case is whether the search warrant issued by respondent Judge Aquino, which
permits the search and seizure of the personal effects of Dr. Verstuyft, an official of the WHO entitled to
diplomatic immunity, is valid.

Ruling of the Supreme Court:

The Supreme Court granted the writs of certiorari and prohibition, rendering the search warrant null and
void. The Court found that respondent Judge Aquino acted without jurisdiction and with grave abuse of
discretion in not quashing the search warrant, disregarding the diplomatic immunity of Dr. Verstuyft. The
Court emphasized that the executive branch of the Philippine Government had recognized and affirmed
the diplomatic immunity of Dr. Verstuyft, and this recognition was a matter of political question, making
it the duty of the courts to accept the claim of immunity upon the suggestion of the Solicitor General or
other officers acting under his direction. Furthermore, the Court noted that the search warrant
proceedings should not have continued before the judge, and any belief of an abuse of diplomatic
immunity should have been handled through the diplomatic channels as stipulated in the Convention on
the Privileges and Immunities of the Specialized Agencies of the United Nations. The Court also
expressed concern over the lack of coordination between different government departments in this
matter, which allowed the COSAC officers to oppose the quashal of the search warrant. The Court
considered this lack of coordination a serious matter, given the provisions of Republic Act 75, which
safeguards the jurisdictional immunity of diplomatic officials in the Philippines. Consequently, the search
warrant was declared null and void, and the respondent court was ordered to desist from further
proceedings in the case. No costs were awarded.
let's break down the ruling further:

Diplomatic Immunity Acknowledged: The Supreme Court emphasized that Dr. Leonce Verstuyft, as an
official of the World Health Organization (WHO), was entitled to diplomatic immunity. This diplomatic
immunity was recognized and affirmed by the executive branch of the Philippine Government. This
recognition is significant because, in international law, diplomatic immunity is a political question. Courts
should typically defer to the determination made by the executive branch regarding diplomatic
immunity.

Separation of Powers and Political Question: The Court underscored the principle of separation of
powers, highlighting that diplomatic immunity is essentially a matter of politics and international
relations. Therefore, the judiciary should refrain from questioning or interfering with decisions made by
the executive branch regarding diplomatic immunity. In this case, the executive branch, including the
Secretaries of Foreign Affairs and Finance, and the Solicitor General, confirmed Dr. Verstuyft's diplomatic
immunity.

Proper Remedy for Diplomatic Immunity Disputes: The Court noted that when there is any belief of
abuse of diplomatic immunity, it is not the role of the judiciary to deal with it through search warrant
proceedings. Instead, it should be handled through diplomatic channels. In this case, the Convention on
the Privileges and Immunities of the Specialized Agencies of the United Nations outlined a specific
procedure for consultations between the Host State (the Philippines) and the international organization
(WHO) to determine whether there has been an abuse of diplomatic privileges and how to address it.

Concern Over Lack of Coordination: The Court expressed concern about the lack of coordination
between various government departments. It noted that despite the clear recognition of diplomatic
immunity by the executive branch, the COSAC officers pursued the search warrant, which could have
been avoided if the different departments had worked together more effectively. This lack of
coordination could potentially embarrass the Philippine Government in international relations.

Relevance of Republic Act 75: The Court emphasized the significance of Republic Act 75, a law enacted to
safeguard the jurisdictional immunity of diplomatic officials in the Philippines. The Act declared null and
void any writs or processes that sought to arrest or imprison a diplomatic official or seize their property.
It even made it a penal offense to obtain or enforce such writs. This law underscores the importance of
respecting and upholding diplomatic immunity, and it should have informed the actions of the COSAC
officers and the court.

In summary, the Supreme Court's ruling emphasized the importance of respecting diplomatic immunity
as recognized by the executive branch of the government. It underscored the political nature of
diplomatic immunity and the need for the judiciary to defer to the executive's determinations in such
matters. Additionally, the Court highlighted the proper procedures for addressing potential abuses of
diplomatic privileges and expressed concern about the lack of coordination between government
departments. The ruling ultimately nullified the search warrant and ordered the respondent court to
cease any further proceedings in the case.
 4. Case Digest: G.R. No. 125865 (January 28, 2000)

Petitioner: Jeffrey Liang (Huefeng)

Respondent: People of the Philippines

Facts:

Jeffrey Liang (Huefeng), the petitioner, worked as an economist at the Asian Development Bank (ADB). In
1994, he was charged with two counts of grave oral defamation against a fellow ADB worker, Joyce
Cabal. The charges were filed in the Metropolitan Trial Court (MeTC) of Mandaluyong City. Subsequently,
petitioner was arrested based on a warrant issued by the MeTC. Bail was set at P2,400.00 per criminal
charge, and he was released into the custody of the ADB's Security Officer.

The following day, the MeTC judge received an "office of protocol" communication from the Department
of Foreign Affairs (DFA), asserting that petitioner was covered by immunity from legal process under
Section 45 of the Agreement between the ADB and the Philippine Government regarding the
Headquarters of the ADB. Relying on this communication and without notifying the prosecution, the
MeTC judge dismissed the two criminal cases. The prosecution filed a motion for reconsideration, which
was opposed by the DFA. When the motion was denied, the prosecution filed a petition for certiorari and
mandamus with the Regional Trial Court (RTC) of Pasig City. The RTC set aside the MeTC's rulings and
ordered the enforcement of the previously issued arrest warrant. After the motion for reconsideration
was denied, petitioner appealed the case to the Supreme Court.

Issue:

The main issue in this case is whether Jeffrey Liang (Huefeng) is covered by immunity from legal process
under the Agreement between the ADB and the Philippine Government and whether the dismissal of
the criminal cases against him by the MeTC based on the DFA's communication was proper.

Ruling:

The Supreme Court ruled against Jeffrey Liang (Huefeng) and in favor of the People of the Philippines.
The Court made the following key points in its ruling:

No Blind Adherence to DFA Communication: Courts cannot blindly accept the DFA's communication as
conclusive evidence of immunity. The DFA's determination of immunity is preliminary and does not bind
the courts. Dismissing the cases without notice to the prosecution violated the right to due process,
which applies to both the accused and the prosecution.

Immunity Is Not Absolute: Section 45 of the Agreement provides immunity for ADB officers and staff
when they act in their official capacity, but this immunity is not absolute. It is subject to the exception
that the acts were done in an "official capacity." The prosecution should have had the opportunity to
rebut the DFA protocol and present evidence to contest the claim of immunity.

Immunity Does Not Cover Slander: Immunity agreements do not cover the commission of crimes, such
as defamation, in the name of official duty. Committing a crime is not part of an official's duty, and public
officials may be held personally liable for acts done with malice or outside the scope of their authority.
Vienna Convention on Diplomatic Relations: Even if petitioner were considered a diplomatic agent, the
Vienna Convention on Diplomatic Relations grants immunity from criminal jurisdiction only for actions
related to professional or commercial activities outside the official functions. Committing a crime is not
considered part of official duty.

Preliminary Investigation Not Required: Preliminary investigation is not mandatory in cases under the
jurisdiction of the MeTC. It is a statutory right that may be invoked only when specifically granted by law.
The absence of preliminary investigation does not affect the court's jurisdiction or the validity of the
information.

Therefore, the Supreme Court denied the petition and upheld the RTC's decision to set aside the MeTC's
dismissal of the criminal cases, allowing them to proceed.