G.R. No. L-18044 - People vs. Valle

Ambrosia Valle was charged with estafa in Criminal Case No. D-091007 before the Municipal Court of Manila.
To secure her provisional release, Valle filed a bail bond subscribed by Alto Surety & Insurance Co., Inc. in the sum of P800.00.

After trial, the court promulgated its decision on September 14, 1959, convicting Valle and sentencing her to 3 months and 11 days of arresto mayor, ordering her to indemnify the offended party P180.00, with subsidiary imprisonment in case of insolvency, and to pay costs.
For the purpose of appealing the decision, Valle filed an appeal accompanied by a new appeal bond in the sum of P500.00, which included several conditions:

Valle’s obligation to appear and answer the charge in any court where the trial might continue.
A requirement that she remain amenable to the orders and processes of the court.
Provisions for the payment of any fine the appellate court might direct, isolation of judgment by surrender if necessary, or appearance for a new trial in case the cause was remanded.
A stipulation that failure to comply with these conditions would obligate the surety to pay P500.00 to the Republic of the Philippines.

On September 14, 1959, Valle appeared before the trial court where the decision was promulgated.
The trial court further ordered her appearance on September 29, 1959—the final day for perfecting her appeal—along with the filing of her appeal bond.
On September 29, Valle requested an extension until the afternoon to file her notice of appeal and the appeal bond; the request was granted with a warning to return later, but she ultimately failed to do so.

On October 1, 1959, the court issued an order stating that since Valle had not filed a notice of appeal nor the appeal bond, and had not surrendered for execution of judgment, the bail bond would be confiscated and a warrant of arrest issued, with execution postponed until her arrest.
The arrest order was received by Alto Surety on October 3, 1959, and on October 14, 1959, the appellant surrendered Valle to the trial court, where she was immediately committed to prison.
Alto Surety then filed a motion on October 15 to have the confiscation order lifted and the bond canceled, which was denied on October 17, 1959.
On October 22, 1959, Alto Surety filed a notice of appeal from the orders dated October 1 and October 17, 1959, prompting the case to be forwarded to the Supreme Court for review on questions of law.

Postponing the execution of its judgment of conviction after its promulgation on September 14, 1959.
Releasing Valle after promulgation without the appellant’s knowledge or consent.
Confiscating the bail bond even after Valle had appeared before the court on the date of promulgation and on the subsequent hearing – September 29, 1959.
Denying the appellant’s motion to lift the order of confiscation of its bail bond.

It was also argued that such actions should reduce the appellant’s liability under the bond.

Postponing the immediate execution of its judgment of conviction after its promulgation.
Releasing the accused Valle without the appellant’s consent following the promulgation of the judgment.
Confiscating the bail bond after Valle had been produced on the day of judgment promulgation and on a subsequent hearing date.
Denying the motion filed by the appellant to lift the order of confiscation of the bail bond.

Valle was surrendered to the trial court shortly after the bond was ordered confiscated and her arrest was decreed.
The lower court’s proceedings and actions provided adequate grounds for maintaining the surety’s obligations.