Facts:

The case at hand is Agustin Dayoan vs. Manuel Blanco, Judge of the Court of First Instance of Ilocos Sur, and Segundo Dayoan, with G.R. No. L-736 decided on October 31, 1946. The petitioner, Agustin Dayoan, was confined in the provincial jail of Ilocos Sur for contempt of court. The contempt charge arose from Civil Case No. 2817, filed by Segundo Dayoan against Agustin Dayoan on January 15, 1946, for disobeying a judicial order. On May 18, 1946, Judge Manuel Blanco rendered a judgment finding Agustin Dayoan and Marianito Ipalari guilty of contempt for failing to deliver 13 uyones of palay to Segundo Dayoan, as mandated by a previous court order dated October 25, 1944. Agustin Dayoan was informed of the judgment on June 8, 1946, and subsequently filed a motion for bail on June 12, 1946, which was denied by the court on June 15, 1946. He submitted a notice of appeal on July 3, 1946, but the Provincial Fiscal set the bail at P500.00 on July 25, 1946, which was later denied by Ju...

Facts:

Background and Parties

• Petitioner: Agustin Dayoan, who was charged with contempt of court.
• Respondents:

- Manuel Blanco, Judge of the Court of First Instance of Ilocos Sur. - Segundo Dayoan, who initiated the contempt proceedings.

Initiation of Contempt Proceedings

• On January 15, 1946, in Civil Case No. 2817 of Ilocos Sur, Segundo Dayoan charged Agustin Dayoan with contempt, alleging non-compliance with a judicial order.
• The judicial order in question dated from October 25, 1944, required Agustin Dayoan (as depositary) and Marianito Ipalari (as special administrator) to deliver 13 uyones of palay to Segundo Dayoan.
• The order was based on earlier evidence that the administration of 42 hectares of land produced a canon equivalent to 80 uyones of palay for the owner, with a specific fractional allocation computed in favor of the complainant.

Proceedings and Judgment on Contempt

• On May 18, 1946, after hearing the parties:

- Judge Manuel Blanco rendered a judgment finding that the respondents had been in contempt for retaining the palay contrary to the court order. - The judgment detailed the production, the conversion of yield into uyones of palay, and the non-compliance with the October 25, 1944 order. - Plaintiff’s declarations and exhibits concerning the crop yield. - Admissions by one of the respondents regarding possession of the palay and failure to deliver it, shifting blame as a means to avoid personal responsibility.

Notification, Appeal, and Bail Requests

• Agustin Dayoan was duly informed on June 8, 1946, of the judgment while he was already confined in the provincial jail.
• On June 12, 1946, while still in confinement, he moved for permission to post bail, claiming the need to secure legal counsel and raise a petition for a new trial.
• The bail petition was objected to by Segundo Dayoan and was subsequently denied on June 15, 1946.
• Agustin Dayoan filed a notice of appeal (pleading dated June 3, 1946) on July 3, 1946.
• On July 25, 1946, the Provincial Fiscal, in absence of the presiding trial judge, fixed the bail bond for provisional release at P500.00.
• On August 5, 1946, Agustin Dayoan moved that the P500.00 bond be approved and that his appeal record be certified and forwarded.
• Segundo Dayoan objected, arguing that the appeal had not been perfected within the prescribed time.
• On August 22, 1946, Judge Ceferino de los Santos declined to approve the bond and to certify the appeal record on grounds that:

- The notice of appeal was submitted late (beyond the fifteen-day limit from the June 8 notification of the commitment order). - Relevant rules (Section 10 of Rule 64 and Section 6, Rule 116) were not complied with.

Petitioner's Arguments and Additional Contentions

• Petitioner maintained that he should not be kept indefinitely in jail for failing to deliver the 13 uyones of palay because:

- He contended that he had disposed of the palay, hence his inability to perform the delivery. - He argued that his situation did not fall within the ambit of Section 7 of Rule 64, which penalizes the omission to do an act that remains within the accused’s power to perform.

Dissenting Opinion (by Perfecto, J.)

• The dissent emphasized that:

- The original judicial order (October 25, 1944) did not clearly mandate that Agustin Dayoan personally ensure the delivery of the 13 uyones of palay. - Petitioner’s inability to deliver the crop due to consuming it was being conflated with a failure to comply with a judicial directive. - Petitioner’s detention, initiated prior to his filing of the appeal and his restricted access to legal resources, amounted to a miscarriage of justice. - Immediate release or provisional release on a bail of P100.00. - Forwarding of the record of Civil Case No. 2817 to the appellate court to enable proper review.

Issue:

Procedural and Timeliness Concerns

• Whether Agustin Dayoan’s notice of appeal, filed on June 3, 1946, was timely, given that he was notified of the judgment on June 8, 1946.
• Whether the filing of the appeal and the subsequent motions were in strict conformity with the required timelines under Section 10 of Rule 64 and Section 6 of Rule 116 of the Judicial Regulations.

Jurisdiction Over Bail and Release

• Whether the trial court or the Provincial Fiscal had the authority to fix the amount of the bail (P500.00) for provisional release during the appeal.
• Whether the petitioner's right to provisional release on bail was effectively compromised by procedural technicalities and his alleged inability to perform the order (delivery of 13 uyones of palay).

Substantive Compliance with the Court Order

• Whether Agustin Dayoan’s action (or inaction) in retaining or disposing of the palay constituted willful contempt, or if there were grounds to consider his inability to perform as excusable.
• Whether the requisites for contempt—specifically the requirement that the accused must be given a chance to perform the mandated act—were satisfied in this case.

Discretion and Authority of the Lower Courts

• Whether the lower courts’ decisions in denying the petitions (for bail and provisional release) and fixing the bail amount fall within their sound discretion without warranting appellate interference.
• The extent to which the presumption of validity of the original judgment precluded the Supreme Court from re-evaluating the findings on the ability to perform the order.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)