FACTS ISSUE RULING/DISCUSSION
G.R. No. L-5731 June 22, 1954 It is evident, therefore, that the consent of the Philippine Government to the application of
HERBERT BROWNELL, JR., as Attorney General of the Philippine Property Act of 1946 to the Philippines after independence was given, not only
the United States, petitioner-appellee, by the Executive Department of the Philippines Government, but also by the Congress, which
vs. enacted the laws that would implement or carry out the benefits accruing from the operation
SUN LIFE ASSURANCE COMPANY OF CANADA, of the United States law. The respondent-appellant, however, contends that the operation of
respondent-appellant. the law after independence could not have actually taken, or may not take place, because
both Republic Act No. 8 and Republic Act No. 477 do not contain any specific provision
whereby the Philippine Property Act of 1946 or its provisions is made applicable to the
Philippines. It is also contended that in the absence of such express provision in any of the
laws passed by the Philippine Congress, said Philippine Property Act of 1946 does not form
part of our laws and is not binding upon the courts and inhabitants of the country.
G.R. No. 17958 February 27, 1922 On or about June 30, 1920, two boats left matuta, a Dutch possession, for Peta, another Dutch
possession. In one of the boats was one individual, a Dutch subject, and in the other boat
eleven men, women, and children, likewise subjects of Holland. After a number of days of
THE PEOPLE OF THE PHILIPPINE ISLANDS, navigation, at about 7 o'clock in the evening, the second boat arrived between the Islands of
plaintiff-appellee, Buang and Bukid in the Dutch East Indies. There the boat was surrounded by six vintas manned
by twenty-four Moros all armed. The Moros first asked for food, but once on the Dutch boat,
vs. too for themselves all of the cargo, attacked some of the men, and brutally violated two of
the women by methods too horrible to the described. All of the persons on the Dutch boat,
with the exception of the two young women, were again placed on it and holes were made in
LOL-LO and SARAW, defendants-appellants. it, the idea that it would submerge, although as a matter of fact, these people, after eleven
days of hardship and privation, were succored violating them, the Moros finally arrived at
Maruro, a Dutch possession. Two of the Moro marauder were Lol-lo, who also raped one of
the women, and Saraw. At Maruro the two women were able to escape.
Lol-lo and Saraw later returned to their home in South Ubian, Tawi-Tawi, Sulu, Philippine
Islands. There they were arrested and were charged in the Court of First Instance of Sulu with
the crime of piracy
A demurrer was interposed by counsel de officio for the Moros, based on the grounds that
the offense charged was not within the jurisdiction of the Court of First Instance, nor of any
court of the Philippine Islands, and that the facts did not constitute a public offense, under
the laws in force in the Philippine Islands.
G.R. No. L-1325 April 7, 1947 This is a petition for habeas corpus filed by George L. Tubb and Wesley Tedrow, citizens of the
GEORGE L. TUBB and WESLEY TEDROW, United States but residents of the Philippines, under written contract of employment with the
petitioners, Army of the United States. It appears that sometime between January 13, 1947, as appearing
vs. in the "charge sheet" submitted by respondent, the herein petitioners were apprehended by
THOMAS E. GRIESS, respondent. the authorities of the United States Army and have since been held in custody. On January 28,
1947, petitioners were formally charged by said authorities with violations of Articles of War
regarding misappropriation of United States Government property destined for military use,
said acts having been committed within premises occupied by the United States Army under
lease contracts.
Petitioners now come before this Court alleging that they are being unlawfully deprived of
their liberty and that Philippine courts have exclusive jurisdiction over their arrest,
confinement and imprisonment because (1) they are not persons subject to military laws, (2)
martial law is no longer enforced.
G.R. No. L-554 April 9, 1948 Plaintiff-appellant’s indebtedness to the defendant-appellee China Banking Corporation in
HAW PIA, plaintiff-appellant, the sum of P5,103.35 by way of overdraft in current account payable on demand together
vs. with its interests, has been completely paid, on different occasions to the defendant Bank
THE CHINA BANKING CORPORATION, defendant- China Banking Corporation through the defendant Bank of Taiwan, Ltd., that was appointed
appellee. by the Japanese Military authorities as liquidator of the China Banking Corporation.
The trial court held that, as there was no evidence presented to show that the defendant Bank
had authorized the Bank of Taiwan, Ltd., to accept the payment of the plaintiff’s debt to the
said defendant, and said Bank of Taiwan, as an agency of the Japanese invading army, was not
authorized under the international law to liquidate the business of the China Banking
Corporation, the payment has not extinguished the indebtedness of the plaintiff to the said
defendant under Article 1162 of the Civil Code.
WON The Philippine Property Act
of 1946 is part of the law of the
land after independence
WON the CFI has jurisdiction
WON the provisions of the Penal
Code dealing with the crime of
piracy are still in force
WON US has jurisdiction
Whether or not the Japanese
Military Administration had
authority to order the liquidation
or winding up of the business of
defendant-appellee China Banking
Corporation, and to appoint the
Bank of Taiwan liquidator
authorized as such to accept the
payment by the plaintiff-appellant
to said defendant-appellee
There is no question that a foreign law may have extraterritorial effect in a country other than the
country of origin, provided the latter, in which it is sought to be made operative, gives its consent
thereto (express or implied)
it must be stated that the consent of a Senate to the operation of a foreign law within its territory
does not need to be express; it is enough that said consent be implied from its conduct or from that
of its authorized officers.
In the case at bar, our ratification of or concurrence to the agreement for the extension of the
Philippine Property Act of 1946 is clearly implied from the acts of the President of the Philippines
and of the Secretary of Foreign Affairs, as well as by the enactment of Republic Acts Nos. 7, 8, and
477.
1. Pirates are in law hostes humani generis. Piracy is a crime not against any particular
state but against all mankind. It may be punished in the competent tribunal of any
country where the offender may be found or into which he may be carried.
2. laws subsisting at the time of transfer, designed to secure good order and peace in the
community, which are strictly of a municipal character, continue until by direct action
of the new government they are altered or repealed.
ART. 153. The crime of piracy committed against Spaniards, or the subjects of another nation not at
war with Spain, shall be punished with a penalty ranging from cadena temporal to cadena perpetua.
U.S. Crim. Code.: whoever, on the high seas, commits the crime of piracy as defined by the law of
nations, and is afterwards brought into or found in the United States, shall be imprisoned for life.
It is evident that the provisions of the Penal Code now in force in the Philippines relating to piracy
are not inconsistent with the corresponding provisions in force in the United States.
By the Treaty of Paris, Spain ceded the Philippine Islands to the United States. A logical construction
of articles of the Penal Code, like the articles dealing with the crime of piracy, would be that
wherever "Spain" is mentioned, it should be substituted by the words "United States" and wherever
"Spaniards" are mentioned, the word should be substituted by the expression "citizens of the United
States and citizens of the Philippine Islands."
It is a settled principle of International Law that a foreign army allowed to march through a friendly
country or to be stationed in it, by permission of its government or sovereign, is exempt from the
civil and criminal jurisdiction of the place.
this principle has been consistently embodied in treaties of military character among friendly
nations and has been accepted by all the countries of the world. The most authoritative writers on
International Law firmly concur in this rule.
petitioners who belong to the military personnel of that army are charged with violations of Articles
of War for offenses committed in areas under the control of the United States Army, thereby giving
said army jurisdiction over their person and the offenses charged, petition is dismissed,
YES. The Japanese military authorities had power, under the international law, to order the
liquidation of the China Banking Corporation and to appoint and authorize the Bank of Taiwan as
liquidator to accept the payment in question, because such liquidation is not confiscation of the
properties of the bank appellee, but a mere sequestration of its assets which required the
liquidation or winding up of the business of said bank. The sequestration or liquidation of enemy
banks in occupied territories is authorized expressly by the United States Army and Navy Manual of
Military Government and Civil Affairs F.M. 2710 OPNAV 50-E-3.
Maximo HILAO, Class Plaintiffs, Plaintiff-
Appellee, v. ESTATE OF
Ferdinand MARCOS, Defendant-Appellant.
No. 95-15779.
This is a class suit civil case for damages for torture, summary execution, disappearances and
illegal detention of over 9,539 Filipino complainants, filed before the United States courts in
April 1986. It was anchored upon the Alien Tort Claims Act (ATCA) of 1789 which statute
allowed damage suits against foreign entities who have taken refuge in US soil for crimes
committed elsewhere. As the Marcos family had fled to Hawaii upon the victory of the EDSA
Revolution, the Federal District Court of Hawaii assumed jurisdiction over their persons. Upon
the death of Marcos in 1989, his estate was substituted as defendant.
WON Marcos liable The principle of “command responsibility” that holds a superior responsible for the actions of
subordinates appears to be well accepted in U.S. and international law in connection with acts
committed in wartime,
The United States has moved toward recognizing similar “command responsibility” for torture that
occurs in peacetime, perhaps because the goal of international law regarding the treatment of
noncombatants in wartime – “to protect civilian populations and prisoners from brutality” -is similar
to the goal of international human rights law.

G.R. No. 108813 December 15, 1994
JUSMAG PHILIPPINES, petitioner,
vs.
THE NATIONAL LABOR RELATIONS COMMISSION
(Second Division) and FLORENCIO SACRAMENTO,
Union President, JPFCEA, respondents.
Private respondent was one of the seventy-four (74) security assistance support personnel
(SASP) working at JUSMAG-Philippines. 1 He had been with JUSMAG from December 18, 1969,
until his dismissal on April 27, 1992. When dismissed, he held the position of Illustrator 2 and
was the incumbent President of JUSMAG PHILIPPINES-FILIPINO CIVILIAN EMPLOYEES
ASSOCIATION (JPFCEA), a labor organization duly registered with the Department of Labor
and Employment. His services were terminated allegedly due to the abolition of his
position.2He was also advised that he was under administrative leave until April 27, 1992,
although the same was not charged against his leave.
On March 31, 1992, private respondent filed a complaint with the Department of Labor and
Employment on the ground that he was illegally suspended and dismissed from service by
JUSMAG. 3 He asked for his reinstatement.
JUSMAG then filed a Motion to Dismiss invoking its immunity from suit as an agency of the
United States. It further alleged lack of employer-employee relationship and that it has no
juridical personality to sue and be sued
Torture Victim Protection Act: A higher official need not have personally performed or ordered the
abuses in order to be held liable. Under international law, responsibility for torture, summary
execution, or disappearances extends beyond the person or persons who actually committed those
acts--anyone with higher authority who authorized, tolerated or knowingly ignored those acts is
liable for them.
it is apparent that when JUSMAG took the services of private respondent, it was performing a
governmental function on behalf of the United States pursuant to the Military Assistance
Agreement dated March 21, 1947. Hence, we agree with petitioner that the suit is, in effect, one
against the United States Government, albeit it was not impleaded in the complaint. Considering
that the United States has not waived or consented to the suit, the complaint against JUSMAG
cannot not prosper.
Immunity of State from suit is one of these universally recognized principles. In international law,
"immunity" is commonly understood as an exemption of the state and its organs from the judicial
jurisdiction of another state. 16 This is anchored on the principle of the sovereign equality of states
under which one state cannot assert jurisdiction over another in violation of the maxim par in parem
non habet imperium (an equal has no power over an equal).
As it stands now, the application of the doctrine of immunity from suit has been restricted to
sovereign or governmental activities ( jure imperii). 22 The mantle of state immunity cannot be
extended to commercial, private and proprietary acts ( jure gestionis).

We also hold that there appears to be no basis for public respondent to rule that JUSMAG is stopped
from denying the existence of employer-employee relationship with private respondent.

He deserves a more compassionate treatment. Unfortunately, JUSMAG is beyond the jurisdiction

of this Court
G.R. No. 79253 March 1, 1993

UNITED STATES OF AMERICA and MAXINE

BRADFORD, petitioners,
vs.
HON. LUIS R. REYES, as Presiding Judge of Branch
22, Regional Trial Court of Cavite, and NELIA T.
MONTOYA, respondents.
G.R. No. 74135 May 28, 1992 M. H. Wylie, in his capacity as assistant administrative officer of the U.S. Naval Station WON American naval officers who The rule that a state may not be sued without its consent, now expressed in Article XVI, Section 3,
supervised the publication of the "Plan of the Day" (POD) which was published daily by the US commit a crime or tortious act of the 1987 Constitution, is one of the generally accepted principles of international law that we
M. H. WYLIE and CAPT. JAMES WILLIAMS, Naval Base station. The POD featured important announcements, necessary precautions, and while discharging official functions have adopted as part of the law of our land under Article II, Section 2.
petitioners, general matters of interest to military personnel. One of the regular features of the POD was still covered by the principle of
vs. the "action line inquiry." On February 3, 1978, the POD published: state immunity from suit the POD as part of their official functions.
AURORA I. RARANG and THE HONORABLE
INTERMEDIATE APPELLATE COURT, respondents. ‘This is not to mention "Auring" who is in herself, a disgrace to her division and to the Office As a rule, public officials can be held personally accountable for acts claimed to have been
of the Provost Marshal. ‘ performed in connection with official duties where they have acted ultra vires or where there is
showing of bad faith.
The private respondent then commenced an action for damages for defamation and libel.
The subject article in the US Newsletter POD dated February 3, 1978 mentions a certain "Auring" as
In response to the complaint, the defendants filed a motion to dismiss anchored on three ". . a disgrace to her division and to the Office of the Provost Marshal."
grounds:
Such act or omission is ultra vires and cannot be part of official duty. It was a tortious act which
1. immune from suit; ridiculed the private respondent.
2. cannot be sued without its consent
3. lack of jurisdiction
G.R. No. L-35645 May 22, 1985 the United States invited the submission of bids for the projects WON USA can be sued State immunity now extends only to acts jure imperil.
UNITED STATES OF AMERICA, CAPT. JAMES E.
GALLOWAY, WILLIAM I. COLLINS and ROBERT
GOHIER, petitioners,
vs.
HON. V. M. RUIZ, Presiding Judge of Branch XV,
Court of First Instance of Rizal and ELIGIO DE
GUZMAN & CO., INC., respondents.
G.R. No. L-11786 September 26, 1958
HARRY LYONS, INC., plaintiff-appellant,
vs.
THE UNITED STATES OF AMERICA (651 United
States Naval Supply Depot, U.S. Navy,
Philippines), defendant-appellee.
[G.R. No. 125865. January 28, 2000]
JEFFREY LIANG (HUEFENG), petitioner, vs.
PEOPLE OF THE PHILIPPINES, respondent.
DECISION
[G.R. No. 142396. February 11, 2003]
KHOSROW MINUCHER, petitioner, vs. HON.
COURT OF APPEALS and ARTHUR SCALZO,
respondents.
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.
Eligio de Guzman & Co., Inc. responded to the invitation and submitted bids. Subsequent
thereto, the company received from the United States two telegrams requesting it to confirm
its price proposals and for the name of its bonding company. In its complaint, the company
alleges that the United States had accepted its bids because "A request to confirm a price
proposal confirms the acceptance of a bid pursuant to defendant United States' bidding
practices."
In June, 1972, the company received a letter which was signed by Wilham I. Collins, Director,
The letter said that the company did not qualify to receive an award for the projects because
of its previous unsatisfactory performance rating.
the company sued the United States of America for specific performance and damages.
plaintiff and defendant entered contract for stevedoring service at the U.S. Naval Base.
Petitioner is an economist working with the Asian Development Bank (ADB). Sometime in
1994, for allegedly uttering defamatory words against fellow ADB worker Joyce Cabal, he was
charged before the Metropolitan Trial Court (MeTC) of Mandaluyong City with two counts of
grave oral defamation.
the MeTC judge received an "office of protocol" from the Department of Foreign Affairs (DFA)
stating that petitioner is covered by immunity from legal process under Section 45 of the
Agreement between the ADB and the Philippine Government.
Based on the said protocol communication that petitioner is immune from suit, the MeTC
judge without notice to the prosecution dismissed the two criminal cases.
Sometime in May 1986, an Information for violation of Section 4 of Republic Act No. 6425,
otherwise also known as the Dangerous Drugs Act of 1972, was filed against petitioner
Khosrow Minucher.
The criminal charge followed a buy-bust operation conducted by the Philippine police narcotic
agents in the house of Minucher, an Iranian national, where a quantity of heroin, a prohibited
drug, was said to have been seized.
Presiding Judge Eutropio Migrino rendered a decision acquitting the two accused.
Minucher filed Civil Case No. 88-45691 before the Regional Trial Court (RTC), Branch 19, of
Manila for damages on account of what he claimed to have been trumped-up charges of drug
trafficking made by Arthur Scalzo.
Scalzo contends that the Vienna Convention on Diplomatic Relations, to which the Philippines
is a signatory, grants him absolute immunity from suit, describing his functions as an agent of
the United States Drugs Enforcement Agency as conducting surveillance operations on
suspected drug dealers in the Philippines believed to be the source of prohibited drugs being
shipped to the U.S., (and) having ascertained the target, (he then) would inform the Philippine
narcotic agents (to) make the actual arrest."
Dr. Leonce Verstuyft is entitled to diplomatic immunity, pursuant to the Host Agreement
executed on July 22, 1951 between the Philippine Government and the World Health
Organization.
When petitioner Verstuyft's personal effects contained in twelve (12) crates entered the
Philippines, they were accordingly allowed free entry from duties and taxes.
WON USA can be sued
WON Respondent has diplomatic
immunity
WON the Judge can determine
diplomatic immunity
In this case the projects are an integral part of the naval base which is devoted to the defense of
both the United States and the Philippines, indisputably a function of the government of the highest
order; they are not utilized for nor dedicated to commercial or business purposes.
MAKASIAR, J., dissenting:
The petition should be dismissed.
Cited Lyons vs. the United States of America
when a sovereign state enters into a contract with a private person the state can be sued upon the
theory that it has descended to the level of an individual from which it can be implied that it has
given its consent to be sued under the contract.
First, courts cannot blindly adhere and take on its face the communication from the DFA that
petitioner is covered by any immunity. The DFAs determination that a certain person is covered by
immunity is only preliminary which has no binding effect in courts.
slandering a person could not possibly be covered by the immunity agreement because our laws do
not allow the commission of a crime, such as defamation, in the name of official duty.
under the Vienna Convention on Diplomatic Relations, a diplomatic agent, assuming petitioner is
such, enjoys immunity from criminal jurisdiction of the receiving state except in the case of an action
relating to any professional or commercial activity exercised by the diplomatic agent in the receiving
state outside his official functions.[5] As already mentioned above, the commission of a crime is not
part of official duty.
if the judgment against an official would require the state itself to perform an affirmative act to
satisfy the award, such as the appropriation of the amount needed to pay the damages decreed
against him, the suit must be regarded as being against the state itself, although it has not been
formally impleaded.
the main yardstick in ascertaining whether a person is a diplomat entitled to immunity is the
determination of whether or not he performs duties of diplomatic nature.
The official exchanges of communication between agencies of the government of the two countries,
certifications from officials of both the Philippine Department of Foreign Affairs and the United
States Embassy, as well as the participation of members of the Philippine Narcotics Command in the
buy-bust operation conducted at the residence of Minucher at the behest of Scalzo, may be
inadequate to support the "diplomatic status" of the latter but they give enough indication that the
Philippine government has given its imprimatur, if not consent, to the activities within Philippine
territory of agent Scalzo of the United States Drug Enforcement Agency. The job description of
Scalzo has tasked him to conduct surveillance on suspected drug suppliers and, after having
ascertained the target, to inform local law enforcers who would then be expected to make the
arrest.
this Court is constrained to rule that respondent Arthur Scalzo, an agent of the United States Drug
Enforcement Agency allowed by the Philippine government to conduct activities in the country to
help contain the problem on the drug traffic, is entitled to the defense of state immunity from suit.
It is a recognized principle of international law and under our system of separation of powers that
diplomatic immunity is essentially a political question and courts should refuse to look beyond a
determination by the executive branch of the government, 8 and where the plea of diplomatic
immunity is recognized and affirmed by the executive branch of the government as in the case at
bar, it is then the duty of the courts to accept the claim of immunity upon appropriate suggestion
by the principal law officer of the government, the Solicitor General in this case, or other officer
acting under his direction.
RELLEVE, and CAPTAIN PEDRO S. NAVARRO of the Respondent judge issued on March 3, 1972 upon application on the same date of respondents
Constabulary Offshore Action Center (COSAC), COSAC officers search warrant No. 72-138 for alleged violation of Republic Act 4712 amending
respondents. section 3601 of the Tariff and Customs Code 3 directing the search and seizure of the dutiable
items in said crates.
the Office of the Solicitor General appeared and filed an extended comment stating the official
position of the executive branch of the Philippine Government that petitioner Verstuyft is
entitled to diplomatic immunity, he did not abuse his diplomatic immunity, and that court
proceedings in the receiving or host State are not the proper remedy in the case of abuse of
diplomatic immunity.
G.R. No. 85750 September 28, 1990 A.
INTERNATIONAL CATHOLIC IMMIGRATION As an aftermath of the Vietnam War, the plight of Vietnamese refugees fleeing from South
COMMISSION, petitioner Vietnam's communist rule confronted the international community.
vs
HON. PURA CALLEJA IN HER CAPACITY AS In response to this crisis, on 23 February 1981, an Agreement was forged between the
DIRECTOR OF THE BUREAU OF LABOR RELATIONS Philippine Government and the United Nations High Commissioner for Refugees whereby an
AND TRADE UNIONS OF THE PHILIPPINES AND operating center for processing Indo-Chinese refugees for eventual resettlement to other
ALLIED SERVICES (TUPAS) WFTU respondents. countries was to be established in Bataan
ICMC was one of those accredited by the Philippine Government to operate the refugee
processing center in Morong, Bataan.
Trade Unions of the Philippines and Allied Services (TUPAS) filed with the then Ministry of
Labor and Employment a Petition for Certification Election among the rank and file members
employed by ICMC The latter opposed the petition on the ground that it is an international
organization registered with the United Nations and, hence, enjoys diplomatic immunity.
B.
Initially, IRRI was organized and registered with the Securities and Exchange Commission as a
private corporation subject to all laws and regulations. However, by virtue of Pres. Decree No.
1620, promulgated on 19 April 1979, IRRI was granted the status, prerogatives, privileges and
immunities of an international organization.
the Kapisanan filed a Petition for Direct Certification Election with Region IV, Regional Office
of the Department of Labor and Employment.
IRRI opposed the petition invoking Pres. Decree No. 1620 conferring upon it the status of an
international organization and granting it immunity from all civil, criminal and administrative
proceedings under Philippine laws.
whether or not the grant of
diplomatic privileges and
immunites to ICMC extends to
immunity from the application of
Philippine labor laws
The Court, therefore, holds that respondent judge acted without jurisdiction and with grave abuse
of discretion in not ordering the quashal of the search warrant issued by him in disregard of the
diplomatic immunity of petitioner Verstuyft.
There can be no question that diplomatic immunity has, in fact, been granted ICMC and IRRI being
specialized agencies.
The Executive Branch of the Government that ICMC and IRRI enjoy immunities accorded to
international organizations, which determination has been held to be a political question conclusive
upon the Courts in order not to embarrass a political department of Government.
"Specialized agencies" are international organizations having functions in particular fields.
The theory behind all three propositions is said to be essentially institutional in character. "It is not
concerned with the status, dignity or privileges of individuals, but with the elements of functional
independence necessary to free international institutions from national control and to enable them
to discharge their responsibilities impartially on behalf of all their members. 13 The raison d'etre for
these immunities is the assurance of unimpeded performance of their functions by the agencies
concerned.
ICMC's and IRRI's immunity from local jurisdiction by no means deprives labor of its basic rights.
Section 31 of the Convention on the Privileges and Immunities of the Specialized Agencies of the
United Nations 17 provides that "each specialized agency shall make 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." Moreover, pursuant to Article IV of the Memorandum
of Agreement between ICMC the the Philippine Government, whenever there is any abuse of
privilege by ICMC, the Government is free to withdraw the privileges and immunities accorded.
Neither are the employees of IRRI without remedy in case of dispute with management as, in fact,
there had been organized a forum for better management-employee relationship as evidenced by
the formation of the Council of IRRI Employees and Management (CIEM) wherein "both
management and employees were and still are represented for purposes of maintaining mutual and
beneficial cooperation between IRRI and its employees."
it is inaccurate to state that a certification election is beyond the scope of that immunity for the
reason that it is not a suit against ICMC. A certification election cannot be viewed as an independent
or isolated process. It could tugger off a series of events in the collective bargaining process together
with related incidents and/or concerted activities, which could inevitably involve ICMC in the "legal
process,"