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D’ ARMOURED SECURITY v. ARNULFO ORPIA

FACTS:

The respondents in this case were employed as security guards by D'Armoured Security and Investigation Agency, Inc., the petitioner, and were assigned to Fortune Tobacco, Inc. On February 9, 1995, the respondents filed a complaint for illegal dismissal and various monetary claims against petitioner and Fortune Tobacco. The Labor Arbiter rendered a decision in favor of the respondents, ordering the petitioner to pay them a total sum of ONE MILLION SEVENTY SEVEN THOUSAND ONE HUNDRED TWENTY FOUR AND TWENTY NINE CENTAVOS (P1,077,124.29). Fortune Tobacco appealed the decision, which was ultimately affirmed with modification by the National Labor Relations Commission (NLRC). The NLRC's decision became final and executory, thus making the petitioner solely liable for the awarded amount. The sheriff served a writ of garnishment upon the Chief Accountant of Foremost Farms, Inc., a corporation with whom the petitioner had an existing services agreement, resulting in the garnishment of petitioner's receivables from Foremost. The petitioner filed a motion to quash/recall the writ of execution and garnishment, which was denied by the Arbiter. The petitioner's appeal to the NLRC was dismissed for failure to post a bond within the reglementary period. The Court of Appeals dismissed the petitioner's petition for certiorari and prohibition, leading to the filing of the present petition for review on certiorari. The issue raised in this petition is whether the garnished amount is exempt from execution.

ISSUES:

  1. Whether petitioner's monthly receivables from Foremost Farms, Inc. are exempt from execution.

RULING:

  1. No, the Court of Appeals did not err in holding that petitioner's monthly receivables from Foremost Farms, Inc. are not exempt from execution.

PRINCIPLES:

  • An order of execution of a final and executory judgment is not appealable to prevent endless litigation.

  • Section 1, Rule IV of the NLRC Manual on Execution of Judgment enumerates the properties exempt from execution, which only pertain to natural persons and not to juridical entities.

  • Exemptions under Rule 39 of the Rules of Court and Article 1708 of the New Civil Code are meant to favor laboring men or women whose works are manual, and the exemption applies to salaries, wages, and earnings from personal services rendered by the judgment obligor intended for the support of the judgment debtor's family.

  • The exemption under Section 13 (i) of Rule 39 of the Rules of Court and Article 1708 of the New Civil Code is personal and available only to natural persons, not to juridical persons.

  • The exemption under Section 13 (i) of Rule 39 of the Rules of Court applies only to individual employees, not to the corporate entity.