Facts:

The case involves Virgilio Bon as the petitioner and the People of the Philippines as the respondent, with the decision rendered by the Supreme Court on January 13, 2004. The events leading to the case occurred in Barangay Basud, Municipality of Sorsogon, Province of Sorsogon, Philippines, where Bon, along with co-accused Alejandro Jeniebre, Jr. and Rosalio Bon, was charged with violating Section 68 of Presidential Decree No. 705, as amended. The Information alleged that in January or February 1990, the accused conspired to unlawfully cut, gather, and manufacture into lumber several trees, including four narra trees, one cuyao-yao tree, and one amugis tree, valued at approximately P25,000.00, without the consent of the landowner, Teresita Dangalan-Mendoza, and without the necessary permits.

Upon arraignment on May 16, 1991, all accused pleaded not guilty. The prosecution presented several witnesses, including Teresita Dangalan-Mendoza, who testified about her ownership of t...

Facts:

Case Background

• Virgilio Bon, along with co-accused Alejandro Jeniebre, Jr. and Rosalio Bon, was charged with violating Section 68 of PD 705 (as amended) for illegally cutting, gathering, and manufacturing lumber from trees belonging to Teresita Dangalan-Mendoza.
• The trees involved were four (4) narra trees, one (1) cuyao-yao tree, and one (1) amugis tree, valued at approximately P25,000.00, the removal of which was done without the owner’s consent and without the requisite permits.

Procedural History and Trial Developments

• After arraignment on May 16, 1991, all accused entered pleas of “Not Guilty,” and the case proceeded to trial.
• The prosecution presented evidence consisting of witness testimonies from barangay tanods (e.g., Julian Lascano), private complainants (e.g., Teresita Dangalan-Mendoza), and law enforcement officers, along with documentary evidence such as photographs showing tree stumps and an investigation report by an officer from CENRO.
• During the trial, key evidence included the extrajudicial admission by petitioner's statement—recorded by the presence of witnesses such as Julian Lascano and Manuel Dangalan—who testified that Bon admitted ordering the cutting of the trees.

Evidence and Testimonies

• Prosecution Evidence:
• Witnesses testified that on February 12, 1990, they personally heard Virgilio Bon admit to cutting the trees.
• Additional circumstantial evidence included the discovery of tree stumps and the valuation report of the lumber, which supported the charge of illegal cutting.
• Defense Evidence:
• All accused, including Bon, testified in their defense, denying their involvement in authorizing the cutting of the trees.
• Testimonies by Rosalio Bon and Virgilio Bon provided an alternate narrative claiming that Teresita Dangalan-Mendoza herself was responsible for the tree cutting, or that the incident was tied to personal disputes regarding tenancy and land management.

Judicial and Appellate Rulings

• The Regional Trial Court (RTC) rendered a decision convicting petitioner's and co-accused involvement, imposing an indeterminate penalty with a specific range for prision mayor.
• On appeal, the Court of Appeals (CA) affirmed the RTC’s conviction of Virgilio Bon based on the circumstantial evidence and extrajudicial admission, while acquitting Alejandro Jeniebre, Jr. due to insufficient evidence linking him to the offense.
• The CA, however, modified the penalty imposed on Virgilio Bon, adjusting the term to an indeterminate range of ten (10) years of prision mayor as minimum and fourteen (14) years and eight (8) months of reclusion temporal as maximum.

Issues Leading to the Petition for Review

• Virgilio Bon, through a petition for review under Rule 45, challenged the admissibility of the extrajudicial admission, specifically alleging that the hearsay evidence was improperly admitted and unreliable.
• The petitioner also questioned the credibility and sufficiency of the circumstantial evidence used to convict him, arguing that his statements, taken without counsel during a period when he was a suspect, should not have been admitted.

Issue:

Admissibility of Hearsay Testimony

• Whether the extrajudicial admission—testimonies by barangay tanods and other witnesses recording Bon’s alleged statement—is admissible under the hearsay rule.
• Whether such testimony, even if considered hearsay, may be admitted to prove that the statement was actually made rather than to verify its truth.

Credibility and Sufficiency of the Prosecution’s Evidence

• Whether the circumstantial evidence, including the alleged admission and subsequent conduct (e.g., demanding payment for the cut trees and asking for forgiveness), satisfies the requirements for convicting the accused beyond reasonable doubt.
• Whether the overall chain of evidence—including physical evidence and witness testimonies—creates an unbroken and persuasive link establishing petitioner's guilt.

Procedural and Constitutional Issues

• Whether the absence of counsel during the extrajudicial admission, which was not made during a custodial investigation, affected its admissibility and fairness in light of the accused’s constitutional rights.
• Whether shortcomings in the handling of procedural defenses—as raised by petitioner's challenge regarding hearsay and the credibility of evidence—warranted reversal or nullification of the conviction.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)