GR 49188; (January, 1990) (Digest)
G.R. No. 49188 ; January 30, 1990
PHILIPPINE AIRLINES, INC., petitioner, vs. HON. COURT OF APPEALS, HON. JUDGE RICARDO D. GALANO, Court of First Instance of Manila, Branch XIII, JAIME K. DEL ROSARIO, Deputy Sheriff, Court of First Instance, Manila, and AMELIA TAN, respondents.
FACTS
The case originated from a judgment for damages against Philippine Airlines, Inc. (PAL) in favor of Amelia Tan. The Court of Appeals modified the trial court’s decision, ordering PAL to pay Tan P25,000.00 as damages and P5,000.00 as attorney’s fees. This judgment became final and executory. A writ of execution was issued, and Deputy Sheriff Emilio Z. Reyes was tasked with its enforcement. PAL delivered two checks totaling P30,000.00, payable to Sheriff Reyes, who then encashed them. However, Sheriff Reyes absconded without turning over the proceeds to Tan. Consequently, Tan moved for an alias writ of execution. The trial court granted the motion, issuing an alias writ against PAL. PAL opposed, arguing its obligation was extinguished by payment to the authorized sheriff.
ISSUE
Whether the alias writ of execution was validly issued despite PAL’s payment to the absconding sheriff, thereby discharging its judgment obligation.
RULING
The Supreme Court ruled in favor of PAL and quashed the alias writ of execution. The Court held that payment to a sheriff armed with a valid writ of execution constitutes a valid discharge of the judgment debtor’s obligation. The sheriff is an officer of the law authorized to receive payment on behalf of the judgment creditor. When PAL delivered the checks payable to Sheriff Reyes, and he encashed them, such act was deemed payment in legal contemplation. The Court emphasized that the risk of the sheriff’s misappropriation falls on the judgment creditor, not the debtor who acted in good faith. The ruling is anchored on the principle that to require the debtor to pay again would be unjust, as it would satisfy the debt twice. The creditor’s remedy lies against the errant sheriff for the misappropriated funds. The Court rejected a overly literal application of procedural rules that would sanction such inequity, opting instead for a just and equitable interpretation that prevents the debtor from being penalized for the sheriff’s malfeasance. Thus, PAL’s obligation was deemed extinguished upon payment to the sheriff, making the subsequent alias writ of execution invalid.