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Case Digest - Lasco vs. NLRC

1) Petitioners were dismissed from their employment with the United Nations Revolving Fund for Natural Resources Exploration (UNRFNRE) and filed a case for illegal dismissal and damages. 2) The UNRFNRE claimed the labor arbiter had no jurisdiction over it due to diplomatic immunity as a specialized agency of the UN. 3) The Supreme Court dismissed the petition, finding that specialized UN agencies enjoy diplomatic immunity, but petitioners still had recourse through appropriate dispute settlement procedures under the Convention on Privileges and Immunities of Specialized Agencies.

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0% found this document useful (0 votes)
1K views1 page

Case Digest - Lasco vs. NLRC

1) Petitioners were dismissed from their employment with the United Nations Revolving Fund for Natural Resources Exploration (UNRFNRE) and filed a case for illegal dismissal and damages. 2) The UNRFNRE claimed the labor arbiter had no jurisdiction over it due to diplomatic immunity as a specialized agency of the UN. 3) The Supreme Court dismissed the petition, finding that specialized UN agencies enjoy diplomatic immunity, but petitioners still had recourse through appropriate dispute settlement procedures under the Convention on Privileges and Immunities of Specialized Agencies.

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CASE DIGEST

CASE NO. 9

LASCO VS UNITED NATIONS REVOLVING FUND FOR NATURAL RESOURCES


EXPLORATION (UNRFNRE)

G.R. Nos. 109095-109107 February 23, 1995

ELDEPIO LASCO, RODOLFO ELISAN, URBANO BERADOR, FLORENTINO ESTOBIO,


MARCELINO MATURAN, FRAEN BALIBAG, CARMELITO GAJOL, DEMOSTHENES MANTO,
SATURNINO BACOL, SATURNINO LASCO, RAMON LOYOLA, JOSENIANO B. ESPINA, all
represented by MARIANO R. ESPINA, petitioner,  vs. UNITED NATIONS REVOLVING FUND
FOR NATURAL RESOURCES EXPLORATION (UNRFNRE) represented by its operations
manager, DR. KYRIACOS LOUCA, OSCAR N. ABELLA, LEON G. GONZAGA, JR., MUSIB M.
BUAT, Commissioners of National Labor Relations Commission (NLRC), Fifth Division, Cagayan
de Oro City and IRVING PETILLA, Labor Arbiter of Butuan City, respondents.

FACTS:

Petitioners were dismissed from their employment with private respondent, the United Nations
Revolving Fund for Natural Resources Exploration (UNRFNRE), which is a special fund and
subsidiary organ of the United Nations. The UNRFNRE is involved in a joint project of the
Philippine Government and the United Nations for exploration work in Dinagat Island. Petitioners
are the complainants for illegal dismissal and damages. Private respondent alleged that
respondent Labor Arbiter had no jurisdiction over its personality since it enjoyed diplomatic
immunity.

ISSUE:

WON specialized agencies enjoy diplomatic immunity

HELD:
Petition is dismissed. This is not to say that petitioner have no recourse. Section 31 of the
Convention on the Privileges and Immunities of the Specialized Agencies of the United Nations
states that ³each specialized agency shall make a provision for appropriate modes of settlement of
(a) disputes arising out of contracts or other disputes of private character to which the specialized
agency is a party.´ Private respondent is not engaged in a commercial venture in the Philippines.
Its presence is by virtue of a joint project entered into by the Philippine Government and the United
Nations for mineral exploration in Dinagat Island

CASE DIGEST 
CASE NO. 9
 LASCO VS UNITED NATIONS REVOLVING FUND FOR NATURAL RESOURCES
EXPLORATION (UNRFNRE)
G.R. Nos. 109095-

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