G.R. No. L-8214, December 27, 1913
THE UNITED STATES, plaintiff-appellant, vs. THOMAS R. NICHOL, defendant.

FACTS:
Thomas R. Nichol was charged with the crime of resisting officers of the law in the Court of First Instance of Manila. To secure his provisional liberty, he deposited a sum of money in court as bail in lieu of a bond. After being convicted, Nichol failed to appear to serve his sentence. Consequently, the court ordered the confiscation of the deposit. The order declared the confiscated sum to be the property of the City of Manila. The Insular Government (representing the United States Government in the Philippines) excepted to that portion of the order and appealed, contending that the confiscated money belongs to the Insular Government, not the City of Manila. The City of Manila based its claim on Section 5 of Act No. 1873 , as affirmed by Section 2 of Act No. 1955 (the general appropriation acts).

ISSUE:
Whether the confiscated cash bail deposit, forfeited due to the defendant’s failure to appear, belongs to the Insular Government or the City of Manila.

RULING:
The Supreme Court ruled in favor of the Insular Government. The confiscated sum is the property of the Insular Government, not the City of Manila.

The Court held that Act No. 1873 (the general appropriation bill) did not change the substantive law governing the ownership or destination of money paid into court in judicial proceedings. Its purpose was to regulate accounting methods and the crediting of receipts among bureaus and departments of the Insular Government, not to allocate funds to the City of Manila or its departments. The City of Manila is not a bureau of the Insular Government, and the appropriation act dealt exclusively with Insular bureaus and departments.

Furthermore, under the Code of Criminal Procedure, bail bonds in criminal cases within the original jurisdiction of the Court of First Instance are made payable to the Government of the United States. The Insular Government is its representative in the Philippines. Therefore, a cash deposit in lieu of a bond follows the same destination. In the absence of a specific statute directing otherwise, forfeited bail deposits belong to the Insular Government.

The order of the Court of First Instance was reversed, and the confiscated sum was declared funds of the Insular Government.