G.R. No. 212003 - Philippine Span Asia Carriers Corp. vs. Pelayo

In 1972, Marcial Samson, then City Mayor of Caloocan City, abolished the position of Assistant City Administrator and 17 other local government positions through Ordinance No. 1749.
Delfina Hernandez Santiago, the then Assistant City Administrator, and the other affected employees challenged the abolition before the Court of First Instance (CFI) of Caloocan City, which in 1973 declared the abolition illegal and ordered their reinstatement with back salaries and emoluments.
The City Government of Caloocan appealed, but the appeal was dismissed by the Supreme Court in January 1985 in G.R. No. L-39288-89 as frivolous and dilatory.
Partial payments were made to Santiago in 1986, leaving a balance of P530,761.91. The City later appropriated funds for unpaid back salaries in 1987 but refused to release them.

In 1991, Judge Mauro T. Allarde of RTC Caloocan City, Branch 123, issued a writ of execution for Santiago's remaining claim.
The City again sought relief from the Court of Appeals, which affirmed the writ of execution and the entitlement of Santiago to back wages covering October 1983 to December 1986.
The City Government’s further appeal to the Supreme Court was dismissed in May 1991 (G.R. No. 98366) for being late and lacking merit.
The court issued an alias writ of execution in March 1992, and despite motions by the City to quash it, the writ was enforced.
In July 1992, Sheriff Castillo sold a City vehicle at auction for P100,000, applying proceeds to Santiago’s claim, leaving a balance of P439,377.14 including interest.

The City moved to invalidate the auction sale and claimed municipal properties were exempt from execution, but Judge Allarde denied the motions and ordered auctions of additional City vehicles.
The Civil Service Commission, in Resolution No. 91-1124, ruled Santiago was not entitled to back wages from 1983-1986, but the Supreme Court later overruled the CSC in G.R. No. 102625 (August 1995), affirming Santiago's entitlement based on prior final judgments.
The City Council enacted Ordinance No. 0134 (October 5, 1992), appropriating P439,377.14 plus interest for Santiago’s back salaries.
Mayor Macario A. Asistio, Jr., however, refused to sign the check for payment despite having approved the ordinance.
Judge Allarde ordered the Acting Mayor to sign, but he declined citing lack of authority; subsequently, on May 7, 1993, the Sheriff was commanded to garnish the City’s funds at Philippine National Bank (PNB).
PNB complied with the garnishment order and released a manager’s check for P439,378 to the Sheriff.
The City Government filed a certiorari petition challenging the garnishment and auction sales as irregular and unlawful.

Whether the garnishment of the City of Caloocan’s funds deposited with PNB was valid and lawful, given the general rule that public funds are exempt from execution and garnishment.

Whether the levy and sale at public auction of certain City-owned vehicles were lawful, considering claims of exemption of such properties used for public service.

Whether the alleged procedural irregularities in the auction sale (lack of proper notice, timing, and Sheriff's certificate) invalidate the sale.

Whether the alias writ of execution under which the levies and garnishment were made had expired and thus should not be enforced.