G.R. No. L-5117
MARCELO MANTILE, ET AL., plaintiffs-appellees, vs. ALEJANDRO CAJUCUM, ET AL., defendants-appellants.
January 31, 1910

FACTS:
Plaintiffs Marcelo Mantile, et al. filed an action in the Court of First Instance of Nueva Ecija. During the proceedings, the acting judge issued an injunction against defendants Alejandro Cajucum, et al. on June 26, 1908, which was served on July 3, 1908. On July 6, 1908, the plaintiffs’ attorney filed an affidavit alleging that the defendants had disobeyed the injunction. The defendants appeared, admitting that the acts complained of were done by their aparceros on June 1, 1908 (prior to the injunction’s issuance). The trial court, however, found the defendants guilty of contempt under Section 232 of the Code of Procedure in Civil Actions and sentenced each to pay a fine of P200. The defendants appealed this contempt order by filing a separate bill of exceptions to the Supreme Court.

ISSUE:
Can a judgment in contempt proceedings, arising from a principal case, be reviewed by the Supreme Court through a separate bill of exceptions before a final judgment in the main action?

RULING:
No. The Supreme Court ruled that under Section 240 of the Code of Procedure in Civil Actions, the review of contempt proceedings by the Supreme Court is only permissible after a final judgment has been rendered in the principal action by the Court of First Instance, and when the entire case is regularly brought to the Supreme Court by a bill of exceptions. A separate appeal via a bill of exceptions solely for the contempt judgment, while the main case is still pending in the lower court, is not allowed. Citing Repide vs. Sweeney, the Court reiterated that review of contempt judgments must await the regular appeal of the principal cause. Therefore, the present bill of exceptions, which attempted to appeal only the contempt order, was dismissed.