G.R. No. L-32667. January 31, 1978.
PHILIPPINE NATIONAL BANK, petitioner, vs. COURT OF INDUSTRIAL RELATIONS, GABRIEL V. MANANSALA and GILBERT P. LORENZO, in his official capacity as authorized Deputy sheriff, respondents.

FACTS

The petitioner, Philippine National Bank (PNB), filed this certiorari proceeding to challenge an order of the respondent Court of Industrial Relations (CIR) denying PNB’s motion to quash a notice of garnishment. The garnishment sought to levy on funds of the People’s Homesite and Housing Corporation (PHHC) deposited with PNB’s Quezon City branch. The purpose was to satisfy a final and executory decision of the CIR in favor of the United Homesite Employees and Laborers Association, with private respondent Gabriel V. Manansala as the counsel entitled to attorney’s fees. A writ of execution had been issued, and the notice was served by respondent Gilbert P. Lorenzo, an authorized deputy sheriff of the CIR.
PNB moved to quash the garnishment on two primary grounds. First, it argued that the appointment and service by the CIR’s deputy sheriff were contrary to law, asserting that only the Quezon City sheriff had proper authority. Second, it contended that the PHHC funds “may be public in character” and thus potentially exempt from garnishment. The CIR denied the motion, holding that its Clerk of Court, as Ex-Officio Sheriff under Republic Act No. 4201, had nationwide authority. It also noted the finality of the judgment. PNB’s motion for reconsideration was denied, prompting this petition.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion in denying PNB’s motion to quash the notice of garnishment.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. On the substantive issue, the Court held that the funds of the PHHC, a government-owned and controlled corporation, were not exempt from garnishment. Citing National Shipyard and Steel Corporation v. Court of Industrial Relations, the Court reiterated that such corporations possess a juridical personality separate from the government, with the capacity to sue and be sued. Their funds, though public in origin, are not immune from court processes for enforcing valid monetary judgments. PNB’s hesitant argument that the funds “could be public” was insufficient to invoke the state’s non-suability.
Regarding the procedural objection on the sheriff’s authority, the Court found the issue non-determinative. While prior jurisprudence (Commissioner of Public Highways v. Burgos) indicated limitations on appointing special sheriffs, the CIR correctly relied on the statutory amendment making its Clerk of Court the Ex-Officio Sheriff with national jurisdiction. Even assuming a technical irregularity, it did not constitute a grave abuse of discretion warranting nullification, especially given the long-standing finality of the judgment and the equities favoring the execution of a rightful claim. The Court emphasized that justice would be subverted by allowing technicalities to further delay the execution of a final judgment.