Southeast Asian Fisheries Development Center (SEAFDEC) vs. Acosta | G.R. Nos. 97468-70 September 2, 1993

International Commissions and Administrative Bodies Have A Distinct Juridical Personality Independent of the Municipal Law of the State

SOUTHEAST ASIAN FISHERIES DEVELOPMENT CENTER represented by its Chief, DR. FLOR J. LACANILAO, petitioner, 
vs.
DANILO ACOSTA in his capacity as Labor Arbiter of the National Labor Relations Commission, Regional Arbitration, Branch VI, CORAZON CANTO, DAN BALIAO, ELIZABETH SUPETRAN, CARMELITA FERRER, CATHRYN CONTRADOR, and DORIC VELOSO, respondents.

Facts:

Two labor cases for illegal dismissal was filed against SEAFDEC before the National Labor Relations Commission (NLRC) of Iloilo. SEAFDEC, however, invoked the doctrine of state immunity from suit and claims that the NLRC cannot acquire jurisdiction over it as it is a recognized international organization. 

Issue:

Whether SEAFDEC may invoke the doctrine of state immunity from suit

Ruling:

Yes. It is beyond question that petitioner SEAFDEC is an international agency enjoying diplomatic immunity. 

In the case Southeast Asian Fisheries Development Center-Aquaculture Department vs. NLRC (1992), the Supreme Court has held that SEAFDEC is an international agency beyond the jurisdiction of public respondent NLRC. And that it was established by the Governments of Burma, Kingdom of Cambodia, Republic of Indonesia, Japan, Kingdom of Laos, Malaysia, Republic of the Philippines, Republic of Singapore, Kingdom of Thailand and Republic of Vietnam. xxx

Being an intergovernmental organization, SEAFDEC including its Departments (AQD), enjoys functional independence and freedom from control of the state in whose territory its office is located.

Further, the said case also discussed the doctrine of state immunity,

One of the basic immunities of an international organization is immunity from local jurisdiction, i.e., that it is immune from the legal writs and processes issued by the tribunals of the country where it is found. The obvious 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.