INTERNATIONAL CATHOLIC MIGRATION COMMISSION v. PURA CALLEJA (DIRECTOR, BUREAU OF LABOR RELATIONS)

FACTS:

In G.R. No. 85750, the International Catholic Migration Commission (ICMC) was accredited by the Philippine Government to operate a refugee processing center. The Trade Unions of the Philippines and Allied Services (TUPAS) filed a petition for certification election among ICMC employees, but ICMC opposed it on grounds of diplomatic immunity. The Bureau of Labor Relations (BLR) ordered the conduct of a certification election, which ICMC sought to dismiss through a petition for certiorari.

In G.R. No. 89331, the International Rice Research Institute (IRRI) claimed immunity from Philippine labor laws in relation to a certification election petition. IRRI argued that as an international organization, it enjoys diplomatic immunity.

Both cases raised the issue of whether diplomatic privileges and immunities extend to immunity from the application of Philippine labor laws. ICMC and IRRI argued in favor of diplomatic immunity, while the BLR and the Solicitor General argued that Philippine labor laws should prevail.

In the case of Simmon Manufacturing Corporation (SMC), the company appealed to the Secretary of Labor and Employment seeking a reversal of the BLR Director's decision. The BLR Director ruled that the assignment of sales routes to salesmen violated the Constitution and the Labor Code. SMC argued that the decision had become final and unappealable, but the SOLE entertained the appeal citing a provision in Republic Act No. 6715.

ISSUES:

  1. Whether Article 3 of Pres. Decree No. 1620, which grants IRRI the status, privileges, prerogatives, and immunities of an international organization, is unconstitutional for depriving Filipino workers of their right to form trade unions.

  2. Whether or not the International Catholic Migration Commission (ICMC) and International Rice Research Institute (IRRI) are immune from local jurisdiction.

  3. Whether or not the grant of immunity from local jurisdiction deprives labor of their basic rights.

  4. Whether or not the employees of the International Rice Research Institute (IRRI) have the right to self-organization despite the grant of immunity to IRRI under Presidential Decree No. 1620.

  5. Whether or not a certification election falls within the scope of immunity granted to IRRI.

RULING:

  1. The Court ruled that Article 3 of Pres. Decree No. 1620 is not unconstitutional. The grant of diplomatic immunity to IRRI, as an international organization, is based on the Memorandum of Agreement and the Convention on the Privileges and Immunities of Specialized Agencies. The Executive Branch of the government has recognized and affirmed these immunities, and the Court upholds this determination as a political question conclusive upon the Courts.

  2. Yes, ICMC and IRRI are immune from local jurisdiction. The granting of immunity is necessitated by their international character and purpose, in order to avoid partiality and interference by the host country. The purpose of immunity is to ensure the unimpeded performance of their functions and to shield the affairs of international organizations from political pressure or control.

  3. No, the grant of immunity does not deprive labor of their basic rights. The employees of ICMC and IRRI are not without recourse in case of disputes, as mechanisms for settlement of disputes are provided for. The privileges and immunities granted to the organizations and their officials may be withdrawn if there is an abuse of such privileges and immunities.

  4. The employees of IRRI have the right to self-organization. The existence of a union within IRRI proves that Presidential Decree No. 1620, which grants IRRI the status, privileges, and immunities of an international organization, does not deprive its employees of this right.

  5. A certification election falls within the scope of immunity granted to IRRI. While IRRI may be immune from legal process, including any civil, penal, and administrative proceedings, it cannot be viewed as being immune from a certification election. A certification election can trigger a series of events in the collective bargaining process, which may involve IRRI in legal processes related to the election. This is in line with the principle that clauses on jurisdictional immunity are standard provisions in the constitutions of international organizations, protecting the organization, its property, and assets.

PRINCIPLES:

  • International organizations and specialized agencies are granted diplomatic immunity and privileges as recognized and affirmed by the Executive Branch of the government.

  • The determination of diplomatic immunity is a political question conclusive upon the Courts.

  • Courts should not exercise jurisdiction that would embarrass the executive arm of the government in conducting foreign relations.

  • International organizations and specialized agencies have international legal personality and are capable of exercising specific rights, duties, and powers.

  • The United Nations is an example of an international organization dedicated to promoting world peace.

  • Specialized agencies are international organizations with specific functions in particular fields.

  • The grant of international immunities to international organizations is based on three principles: (a) protection of institutions against control or interference by any one government, (b) prevention of any country from deriving national financial advantage, and (c) granting of facilities for conduct of official business to international organizations. The purpose of these immunities is to ensure the unimpeded performance of their functions.

  • Immunity from local jurisdiction is necessary for international organizations due to their international character and objectives, to avoid interference by the host country.

  • granting of immunity does not deprive individuals of their basic rights, as there are mechanisms for dispute settlement and the possibility of withdrawing privileges and immunities in cases of abuse.

  • The right to self-organization is preserved even if an international organization is granted immunity.

  • Immunity granted to international organizations includes protection from various legal processes, including certification elections, which are integral to the collective bargaining process.

  • Jurisdictional immunity is a standard provision in the constitutions of international organizations, protecting the organization, its property, and assets.