G.R. No. L-17874; August 31, 1963
NATIONAL SHIPYARDS & STEEL CORPORATION, petitioner, vs. COURT OF INDUSTRIAL RELATIONS, and JOSE ABIDAY, ET AL., respondents.
FACTS
The case originated from a petition filed by laborers against the National Shipyards & Steel Corporation (NASSCO) for additional compensation for night, Sunday, and holiday work. The Court of Industrial Relations (CIR) ordered NASSCO to pay, and after a series of partial reports by its chief examiner, writs of execution were issued. The sheriff garnished funds from NASSCO’s bank accounts, and the amounts were distributed to the laborers. In a prior execution involving a different sum, NASSCO did not contest the nature of the garnished funds.
In the execution for the larger sum of P147,274.00, NASSCO moved to stay enforcement, claiming the garnished funds were “public funds” as they were proceeds from government bonds issued under Republic Acts Nos. 1000 and 1396, which it argued were exempt from attachment. The CIR’s Presiding Judge initially ordered the garnishment lifted and required the laborers’ counsel to return the money. However, the CIR en banc reversed this order, noting NASSCO’s failure to raise the exemption claim during the first execution and holding the garnished amount was not government money.
ISSUE
The principal issue is whether the funds garnished from NASSCO’s bank account, alleged to be proceeds from government bonds, are exempt from execution.
RULING
The Supreme Court affirmed the CIR en banc resolution, ruling the funds were not exempt. The legal logic centers on statutory construction and corporate personality. NASSCO relied on Republic Act No. 1000, which states bonds issued under the Act “shall be exempt from attachment, execution or seizure.” The Court applied the principle expressio unius est exclusio alterius (the express mention of one thing excludes others), holding this exemption applies only to the physical bonds themselves, not to the proceeds from their sale. This interpretation is reinforced by the statutory requirement that the exemption be stated on the bonds’ face, a condition impossible to apply to monetary proceeds.
Furthermore, the Court rejected the argument that NASSCO’s funds are public funds immune from garnishment. As a government-owned and controlled corporation created under Executive Order No. 356, NASSCO possesses a separate juridical personality distinct from the national government. It exercises corporate powers, including the capacity to sue and be sued. The law explicitly provides that the government shall not be liable for NASSCO’s debts, underscoring its separate liability. Consequently, NASSCO’s assets, including bank deposits, are subject to court processes like execution to satisfy its obligations. The failure to raise the exemption claim during the first garnishment further undermined its position.
