G.R. No. 152160 - Bon vs. People

Virgilio Bon (petitioner) and Alejandro Jeniebre, Jr., together with Rosalio Bon, were charged with violating Section 68 of Presidential Decree (PD) No. 705, as amended, for illegally cutting, gathering, and manufacturing into lumber timber from private land owned by Teresita Dangalan-Mendoza.
The accusation stated that in January or February 1990, at Barangay Basud, Sorsogon, they unlawfully cut four narra trees, one cuyao-yao tree, and one amugis tree, amounting to approximately 4,315 board feet valued at around P25,000, without the owner's consent or the necessary permits.
Upon arraignment on May 16, 1991, all accused pleaded not guilty.

The prosecution presented witnesses including Nestor Labayane, Teresita Dangalan-Mendoza (private complainant), Barangay Tanod Julian Lascano, Alexander Mendones (CENRO Officer), and Manuel Dangalan.
Prosecution’s testimonies established:

Teresita owns a titled agricultural land (Title No. 6666) located in Basud, Sorsogon, administered by petitioner.
Manuel Dangalan, the private complainant’s brother, and Barangay Captain Nestor Labayane initiated an investigation after reports of illegal timber cutting in the land.
On February 12, 1990, the group including the petitioner inspected the land and found six tree stumps matched to the described trees.
Petitioner admitted ordering the cutting and sawing of trees.
Witness Oscar Narvaez testified he sawed the lumber in January 1990 under Alejandro Jeniebre, Jr.’s instruction.
CENRO Officer Mendones confirmed lack of permits and estimated the lumber volume and value.

Rosalio Bon contended he was in Manila during the time of the offense, alleging the case was filed to eject his father as tenant.
Virgilio Bon stated he was the tenant and had an agrarian dispute with Teresita, denied cutting the trees, and alleged Teresita had the lumber cut.
Alejandro Jeniebre, Jr. denied hiring Narvaez to saw the timber, claiming Narvaez testified against him out of personal grudge.

On August 23, 1993, the trial court convicted Virgilio Bon and Alejandro Jeniebre, Jr. but acquitted Rosalio Bon.
Both Virgilio Bon and Jeniebre appealed the decision to the Court of Appeals (CA).
The CA affirmed Virgilio Bon’s conviction but acquitted Alejandro Jeniebre, Jr., and modified the penalty for Virgilio Bon.
Virgilio Bon filed a petition for review under Rule 45 before the Supreme Court, raising issues on hearsay, admissibility of extrajudicial admissions, and sufficiency of evidence.

Whether the hearsay testimonies of prosecution witnesses who relayed petitioner’s alleged extra-judicial admission, which petitioner denied under oath, are admissible evidence against him.

Whether hearsay testimonies made to potential prosecution witnesses (non-police, non-media) can be admissible as these voluntary admissions are presumably truthful.

To what extent the testimonies of prosecution witnesses recounting petitioner’s alleged admission should be given credence, in light of the possibility that testimonies can be untruthful.

Whether the petitioner’s supposed extra-judicial admission, if any, is constitutionally admissible as evidence against him, especially considering the lack of counsel during such admission.