G.R. No. L-736 - Agustin Dayoan vs. Manuel Blanco, Judge of the Court of 1st Instance of Ilocos Sur, and Segundo Dayoan

Agustin Dayoan was confined in the provincial jail of Ilocos Sur for contempt of court.
He filed several petitions requesting:
1. Release on bail during the pendency of the proceedings.
2. An order for Judge Manuel Blanco (or his successor) to fix the bail amount for provisional release during his appeal.
3. That his appeal from the contempt sentence be given due course.
4. Final liberation upon a finding that the contempt sentence was null and void.
5. Damages against Segundo Dayoan.
The first request for bail was denied on September 14, 1946, and the remaining requests were to be addressed subsequently.

On January 15, 1946, Segundo Dayoan filed a contempt charge against Agustin Dayoan 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 ordered by the court.
The court ordered their arrest until compliance with the order.

Agustin Dayoan was informed of the judgment on June 8, 1946, after being jailed on June 5, 1946.
He filed a motion for bail on June 12, 1946, which was denied on June 15, 1946, due to Segundo Dayoan's objection.
On July 3, 1946, Agustin Dayoan submitted a notice of appeal, but the Provincial Fiscal set the bail at P500.00 in the absence of the judge.
On August 5, 1946, he moved for approval of the bond and certification of the record on appeal, but Segundo Dayoan objected, claiming the appeal was not perfected in time.

On August 22, 1946, Judge Ceferino de los Santos declined to approve the bond and record, stating that Agustin Dayoan's notice of appeal was late, having been filed more than fifteen days after notification of the judgment.
The court noted that the commitment order was indeed appealable, but the late notice of appeal rendered the court without jurisdiction to entertain it.
The court found that the request for bail was met by the Provincial Fiscal's action, and since the right to appeal had lapsed, there was no need for an appeal bond.

Agustin Dayoan argued that he should not be indefinitely imprisoned for failing to deliver the palay, as he had disposed of it.
The court maintained that the ability to comply with the order was assessed by the committing judicial officer, and Agustin Dayoan failed to take necessary steps for review.
The court emphasized that the discretion to release him from custody rested with the lower court, which could consider various factors, including the time served and the technical nature of the rules that deprived him of a review.