Khoo Boo Boon v. Belle Corporation

Summary

This case involves the enforcement of a labor judgment against a foreign corporation through property levy. Khoo Boo Boon, a Malaysian national, successfully sued his former employer LIRL for illegal dismissal, obtaining a judgment worth over US$1.2 million. When execution proved insufficient, Boon sought to levy real property in Parañaque City that LIRL received as liquidating dividend from a dissolved Filipino corporation. Belle Corporation challenged this levy, claiming it had purchased the property from LIRL. The Supreme Court ruled that foreign stockholders can acquire equitable (though not absolute) interests in real property through corporate liquidation, making such interests leviable for judgment satisfaction. The Court emphasized that a registered notice of levy takes precedence over unregistered sales, and that labor tribunals have limited authority in third-party claims, focusing only on whether the judgment debtor retains leviable interests rather than determining purchaser good faith. The decision balances constitutional restrictions on foreign land ownership with property rights and due process protections.