A judgment directing a government-owned or controlled corporation (GOCC) to "settle the claims" of its employees is a special judgment for the performance of an act other than the payment of a specific sum of money, and its execution cannot be enforced through garnishment; furthermore, even if a GOCC's funds can generally be garnished, a claim for payment of a judgment award against it must first be filed with the Commission on Audit (COA) before execution can proceed.

Danilo Morales and other employees of the National Electrification Administration (NEA) filed a class suit against NEA for the payment of various allowances and longevity pay purportedly authorized under Republic Act No. 6758 (Compensation and Classification Act of 1989). The RTC granted their petition, ordering NEA to settle their claims.

• Danilo Morales and 105 other NEA employees filed a class suit against NEA for payment of rice allowance, meal allowance, medical/dental/optical allowance, children's allowance, and longevity pay under R.A. No. 6758.
• On December 16, 1999, the RTC granted their petition, ordering NEA "to forthwith settle the claims of the petitioners and other employees similarly situated and extend to them the benefits and allowances...as enumerated under Section 5 of DBM CCC No. 10 and their inclusion in the Provident Funds Membership, retroactive from the date of their appointments up to the present or until their separation from the service."
• The RTC issued a Writ of Execution on February 22, 2000, directing NEA to settle the claims and cause inclusion in the Provident Fund.
• A Notice of Garnishment was issued against NEA's funds with DBP for P16,581,429.00.
• NEA filed a Motion to Quash, arguing that public funds are exempt from execution under P.D. No. 1445, but stated willingness to pay if a supplemental budget was provided by the Department of Budget and Management (DBM).
• The RTC, in its Order of May 17, 2000, denied the Motion to Quash but held the implementation of the writ in abeyance for 90 days, directing NEA to report on fund procurement from DBM.
• DBM denied NEA's request for a supplemental budget, stating Morales et al. were not qualified for the benefits.
• The Commission on Audit (COA), in an Indorsement dated March 23, 2000, advised NEA against further payments, citing a prior COA decision (No. 95-074) and stating the RTC may have exceeded its jurisdiction. COA also indicated its intent to question the RTC decision before the Supreme Court.
• Morales et al. filed a Motion to Implement Writ of Execution, which the RTC denied on January 8, 2001, citing SC Administrative Circular No. 10-2000 (on caution in executing money judgments against government agencies). The RTC also denied their petition for contempt.
• Morales et al. filed a petition for certiorari with the CA, which, on July 4, 2002, granted the petition, nullified the RTC's orders, and directed the implementation of the writ of execution, reasoning that NEA, as a GOCC, can be subjected to court processes like garnishment.

• The Court of Appeals erred in directing the implementation of the writ of execution because execution is premature as respondents (Morales, et al.) have yet to file their judgment claim with the Commission on Audit (COA) in accordance with P.D. No. 1445 and SC Administrative Circular No. 10-2000.
• Execution is not feasible without the Department of Budget and Management (DBM) as an indispensable party to the petition for certiorari, as DBM is the department that can certify fund availability.

• The National Electrification Administration (NEA), as a government-owned or controlled corporation (GOCC), can be subjected to court processes, including garnishment of its properties, just like any other corporation.
• NEA can no longer take shelter under P.D. No. 1445 and SC Administrative Circular No. 10-2000 because it is a GOCC.
• The reason for the suspension of the writ of execution (awaiting DBM funding) no longer exists as DBM had already denied NEA's request.

• Whether the Court of Appeals committed an error of law in ordering the implementation of a writ of execution through garnishment against the funds of the National Electrification Administration (NEA).
• Whether the Regional Trial Court's decision was a judgment for a specific sum of money susceptible to execution by garnishment.
• Whether a claim for payment of a judgment award against a GOCC like NEA must first be filed with the Commission on Audit (COA) before execution can proceed.

• Yes, the Court of Appeals committed an error. The petition of NEA is meritorious.
• The December 16, 1999 RTC Decision is not a judgment for a specific sum of money susceptible of execution by garnishment. It is a special judgment directing petitioners to "settle the claims" of respondents, requiring the performance of an act other than the payment of money, governed by Section 11, Rule 39 of the Rules of Court.
• Garnishment, under Section 9(c), Rule 39, is proper only when the judgment to be enforced is for payment of a sum of money. The RTC exceeded its judgment when its Writ of Execution directed payment of specific benefits and when it countenanced garnishment for P16,581,429.00, an amount not awarded in its decision.
• While NEA is a GOCC with a juridical personality separate from the government and can be sued, and its funds may generally be garnished, a claim for payment of the judgment award must first be filed with the COA.
• Under Commonwealth Act No. 327, as amended by P.D. No. 1445, the COA has primary jurisdiction to examine, audit, and settle all debts and claims of any sort due from or owing the Government or its instrumentalities, including GOCCs.
• The RTC acted prudently in halting the writ's implementation to allow recourse to COA processes. The CA erred in reversing the RTC and directing immediate implementation through garnishment.

• Execution of Special Judgments (Rule 39, Section 11, Rules of Court) — This rule governs the execution of judgments requiring the performance of any act other than the payment of money or the sale or delivery of real or personal property. It involves serving a certified copy of the judgment upon the party or person required to obey it, who may be punished for contempt if they disobey. This was applied because the RTC's decision directing NEA to "settle the claims" was deemed a special judgment, not one for a specific monetary sum, making garnishment an improper execution method.
• Garnishment of Debts and Credits (Rule 39, Section 9(c), Rules of Court) — This rule allows an officer to levy on debts due the judgment obligor and other credits in the possession or control of third parties to satisfy a money judgment. It was applied to show that garnishment is only proper for judgments for a sum of money, which the RTC's initial decision was not. The Court found the RTC exceeded its judgment when it allowed garnishment based on a writ that quantified claims not specified in the decision.
• Primary Jurisdiction of the Commission on Audit (COA) (Commonwealth Act No. 327, as amended by P.D. No. 1445) — This doctrine establishes that the COA has the primary authority to examine, audit, and settle all debts and claims of any sort due from or owing the Government or any of its subdivisions, agencies, and instrumentalities, including GOCCs. It was applied to rule that even if NEA, as a GOCC, can be sued and its funds garnished, any money claim arising from a judgment against it must first be filed with the COA for determination and settlement before execution can proceed.
• Execution of Money Judgments Against Government Entities (SC Administrative Circular No. 10-2000) — This circular enjoins judges to observe utmost caution, prudence, and judiciousness in issuing writs of execution to satisfy money judgments against government agencies and local government units, emphasizing that disbursements must be covered by corresponding appropriations and claims must generally be filed with the COA. The Court cited this to support the RTC's prudence in halting execution pending COA processes.

• "Indeed, respondents cannot proceed against the funds of petitioners because the December 16, 1999 RTC Decision sought to be satisfied is not a judgment for a specific sum of money susceptible of execution by garnishment; it is a special judgment requiring petitioners to settle the claims of respondents in accordance with existing regulations of the COA."
• "In its plain text, the December 16, 1999 RTC Decision merely directs petitioners to 'settle the claims of [respondents] and other employees similarly situated.' It does not require petitioners to pay a certain sum of money to respondents."
• "Garnishment is proper only when the judgment to be enforced is one for payment of a sum of money."
• "However, before execution may proceed against it, a claim for payment of the judgment award must first be filed with the COA."
• "All told, the RTC acted prudently in halting implementation of the writ of execution to allow the parties recourse to the processes of the COA."

• Philippine National Bank v. Court of Industrial Relations (81 SCRA 314) — Cited by the CA to support its holding that NEA, as a GOCC, may be subjected to court processes like garnishment. The Supreme Court acknowledged this general principle but qualified it with the COA requirement.
• Commissioner of Public Highways v. San Diego (31 SCRA 617) — Cited in SC Administrative Circular No. 10-2000 and by the RTC, stating that government funds and properties may not be seized under writs of execution or garnishment to satisfy judgment, as disbursements must be covered by corresponding appropriation.
• Department of Agriculture v. NLRC (227 SCRA 693) — Cited to support the rule that upon determination of State liability, satisfaction must be pursued according to rules in P.D. No. 1445, meaning claims must first be filed with COA.
• Republic v. Villasor (54 SCRA 84) — Referenced in Department of Agriculture v. NLRC for the principle that government funds cannot be seized by execution or garnishment.
• Parreño v. Commission on Audit (G.R. No. 162224, June 07, 2007) — Cited to affirm that before execution may proceed against a GOCC, a claim for payment of the judgment award must first be filed with the COA.

• Rules of Court, Rule 39, Section 11 (Execution of special judgments) — Defines how judgments requiring the performance of an act other than payment of money are executed. Relevant because the RTC decision was classified as a special judgment.
• Rules of Court, Rule 39, Section 9(c) (Garnishment of debts and credits) — Describes the process of garnishment for enforcing money judgments. Relevant because garnishment was improperly attempted to enforce a special judgment.
• Presidential Decree No. 1445 (Government Auditing Code of the Philippines), Section 4 — States fundamental principles governing financial transactions of government agencies, including that no money shall be paid out of public treasury except in pursuance of an appropriation law. NEA initially invoked this.
• Presidential Decree No. 1445, Sections 49-50 — Outlines the procedure for filing money claims against the government with the COA. Relevant to the requirement that claims against NEA be filed with COA.
• Commonwealth Act No. 327, as amended by Section 26 of P.D. No. 1445 — Grants COA primary jurisdiction to examine, audit, and settle all debts and claims due from or owing the Government or its instrumentalities, including GOCCs. This is central to the ruling requiring prior COA filing.
• Presidential Decree No. 269 — The law creating NEA as a GOCC. Relevant to establish NEA's status and capacity to sue and be sued.
• SC Administrative Circular No. 10-2000 — Enjoins judges to observe caution in issuing writs of execution for money judgments against government agencies, emphasizing COA procedures. Relevant to the RTC's decision to halt execution.
• Republic Act No. 6758 (Compensation and Classification Act of 1989) — The law under which the respondents initially claimed their benefits.