GR 151325; (June, 2005) (Digest)
G.R. No. 151325 ; June 27, 2005
D’ ARMOURED SECURITY AND INVESTIGATION AGENCY, INC., petitioner, vs. ARNULFO ORPIA, et al., respondents.
FACTS
Respondents, security guards employed by petitioner D’Armoured Security and Investigation Agency, filed a complaint for illegal dismissal and monetary claims. The Labor Arbiter ruled in their favor, ordering petitioner and Fortune Tobacco, Inc. to pay monetary awards. Fortune Tobacco appealed to the NLRC, but petitioner did not. The NLRC modified the decision, dismissing the complaint against Fortune Tobacco, making the award the sole liability of petitioner. This decision became final and executory.
For execution, the Labor Arbiter issued a writ of garnishment on petitioner’s receivables from Foremost Farms, Inc., a client. Petitioner filed a Motion to Quash/Recall the Writ, arguing its receivables were exempt from execution. The Arbiter denied the motion. Petitioner’s appeal to the NLRC was dismissed for failure to post the required appeal bond. The Court of Appeals subsequently dismissed petitioner’s certiorari petition, prompting this review.
ISSUE
Whether the Court of Appeals erred in holding that petitioner’s monthly receivables from Foremost Farms, Inc. are not exempt from execution.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The petition was dismissible as an order of execution of a final judgment is not appealable to forestall endless litigation. On the substantive issue, the Court held that exemptions from execution do not apply to juridical entities like petitioner.
The NLRC Manual on Execution of Judgment enumerates properties exempt from execution, such as family homes, necessary clothing, and tools of trade. These exemptions pertain only to natural persons, not juridical entities. The law protects earnings from personal services necessary for family support, which is inapplicable to a corporation. The Court cited precedent (Pentagon Security and Investigation Agency vs. Jimenez) where a security agency’s claim that its guns were exempt tools was rejected, as the exemption is personal to natural persons. Consequently, petitioner’s corporate receivables are subject to garnishment for satisfying the final labor judgment in favor of the guards.