Jang Lim v. The Court of Appeals

Summary

This case involves the execution of a final Supreme Court labor judgment awarding almost 100 workers separation pay and other benefits from Cotabato Timberland Co., Inc. (CTCI). During execution, CTCI allegedly fraudulently transferred five parcels of land to its sister company M&S Company one month after the Supreme Court decision to evade payment. The Court of Appeals dismissed the workers' challenge on technical grounds. The Supreme Court applied liberal construction of procedural rules given the number of affected workers and apparent fraud scheme. It held that the property transfers were presumptively fraudulent under Article 1387 of the Civil Code since they occurred after judgment was rendered, shifting the burden to respondents to prove good faith. The Court allowed levy on five fraudulently transferred parcels but protected one parcel legitimately owned by M&S since 1993. The decision demonstrates the Court's commitment to protecting workers' rights against corporate schemes designed to defeat final labor judgments.