A recent ruling by the Supreme Court clarified that the immunity granted to officials and personnel of international organizations only covers actions performed in their official capacities. The decision came after a complaint for damages filed by Matthew Westfall against officials of the Asian Development Bank (ADB) was dismissed by the court.
Westfall had applied for a position at the ADB but was not selected. He claimed that statements made by ADB officers during the selection process were defamatory and damaging to his reputation. Despite filing a complaint for damages, the Regional Trial Court of Makati City dismissed his case, stating that the ADB officials were entitled to “functional immunity” for acts performed in their official capacities.
After the Court of Appeals affirmed the RTC’s decision, Westfall petitioned the Supreme Court. The SC initially ordered a remand to the RTC for further inquiry, but ultimately ruled in favor of Locsin and the other ADB officers, dismissing the complaint for damages. The court emphasized that international organizations enjoy immunity to protect them from political pressure and prevent local courts from exerting jurisdiction over them.
The decision, penned by Associate Justice Rodil Zalameda, highlighted that while international organizations have almost absolute immunity, personnel are only immune for acts performed in their official capacities. Personal acts, crimes, and actions contrary to the law are not covered by this immunity. The ruling was made on April 16, 2024.
