G.R. No. L-1419, L-1420, L-1421; July 31, 1947
Case Title: ROSARIO OCHING, ET AL., petitioners, vs. SOTERO RODAS, Judge of First Instance of Manila, and BARTOLOME SAN DIEGO, respondents. (Consolidated with G.R. No. L-1420 and G.R. No. L-1421)

FACTS

The petitioners obtained final monetary judgments against respondent Bartolome San Diego under the Workmen’s Compensation Act. They moved for execution of these judgments in the Court of First Instance of Manila. San Diego opposed the motion, invoking the debt moratorium established by Executive Order No. 25, as amended by Executive Order No. 32. Judge Sotero Rodas denied the motion for execution based on this plea.

ISSUE

Whether the debt moratorium under Executive Order No. 32 applies to suspend the execution of final monetary judgments obtained under the Workmen’s Compensation Act.

RULING

The Supreme Court, in a majority opinion, ruled that the debt moratorium applies. The petition was denied.
The Court held that the pertinent provision of Executive Order No. 32, which suspends the enforcement of payment of “all debts and other monetary obligations,” is comprehensive, plain, and unambiguous. It leaves no room for construction and makes no exception for obligations arising under the Workmen’s Compensation Act. The Court cited settled jurisprudence (Palacios vs. Daza and Tarnate vs. Daza) establishing that the moratorium suspends execution of money judgments. The Court concluded that the order embraces all monetary obligations regardless of their source, the creditor’s indigence, or the debtor’s ability to pay. While expressing sympathy for the petitioners, the Court stated their remedy did not lie with the judiciary.
SEPARATE OPINIONS:
Justice Hilado (DISSENTING), with whom Chief Justice Moran and Justices Pablo and Perfecto concurred, voted to grant the petition. The dissent argued on four main grounds:
1. The Workmen’s Compensation Act implements constitutional social justice policy. The moratorium orders should not be construed to deviate from or nullify this policy, especially given the priority status of compensation claims under the Act.
2. Following the principle that a money judgment constitutes a new debt, the obligation was created by the Supreme Court’s final judgment rendered on December 17, 1946—after the entire Philippines had been liberated. Per the terms of Executive Order No. 32, debts incurred in liberated areas are excluded from the moratorium.
3. The pre-judgment compensation claims were unliquidated, not definite monetary obligations like contract debts, and thus differ from the typical obligations contemplated by the moratorium.
4. Compensation is an item of production cost budgeted by industry and should not be deemed included in the moratorium.
Justice Perfecto (DISSENTING) added that San Diego waived any moratorium defense by actively litigating the compensation cases to a final Supreme Court decision without raising the defense, only invoking it after an execution order was issued. Furthermore, the dissent argued that obligations created by law (like workmen’s compensation) cannot be suspended by executive order without an express repeal, which was absent, and that the moratorium’s purpose to aid the less fortunate is inconsistent with applying it to compensation for laborers.