Case Facts Issues Held Ratio/Ruling

Department of The petitioner DA and Sultan May the writ of NO When the State
Agriculture Security Agency (SSA) entered into a execution be directed waives its
contract for security services to be against the properties immunity, all it
Vs. provided by SSA to the said of the DA to satisfy a does, in effect, is to
governmental entity. final and executory give the other party
NLRC GR judgment? an opportunity to
104269, 227 Guards were deployed by SSA in the prove, if it can, that
SCRA 693 [Nov various premises of the DA. the State has a
11, 1993] liability. The Court
Several Guards of the SSA filed a reiterated Republic
complaint against DA and SSA for v. Villasor: “power
underpayment of wages, of the Courts ends
nonpayment of the 13th month pay when the judgment
etc., is rendered, since
government funds
The Executive Labor Arbiter and properties may
rendered a decision finding the DA not be seized under
jointly and severally liable with SSA writs or execution
for the payment of the money claims or garnishment to
and a writ of execution was satisfy such
accordingly issued. The DA prayed to judgments.
quash the writ of execution with the Disbursements of
NLRC which did not. The DA asserts public funds must
State immunity. be covered by the
correspondent
appropriation as
required by law.”
Government-owned
or controlled
corporations have
juridical
personalities
separate and
distinct from the
government, and
are thus not
covered by State
immunity from suit.
Their funds are
therefore not
exempt from
garnishment.