G.R. No. 252423 - Department of Environment and Natural Resources-Provincial Environment and Natural Resources Office of Virac, Catanduanes vs. Eastern Island Shipping Lines Corp.

Marvin Soria y Sarmiento and Elmer Morauda III y Mirabuna (accused) were charged with violation of Section 77 of Presidential Decree No. 705 (Revised Forestry Code of the Philippines), for possession and transport of 196 pieces of lumber without necessary DENR permits.
The lumber was transported on a ten-wheeler Isuzu dump truck, plate no. ACO 1836, allegedly owned by Eastern Island Shipping Lines Corporation (respondent) and leased to Elmer B. Belen by respondent through a contract dated February 26, 2018.
The lumber and the subject truck were confiscated by law enforcement officers pending trial.

On March 16, 2018, the accused pleaded guilty and were found guilty beyond reasonable doubt of violating P.D. No. 705.
Sentences were imposed, including confiscation of the 196 pieces of lumber and the subject truck.
The RTC ordered the accused to submit documents to prove that the truck was used without the registered owner's knowledge and that there was a lease contract involving Engr. Gene Guerrero.
The accused were allowed to post a bond for temporary liberty pending probation filing.
Law enforcers on March 20, 2018 withheld consent for release of the truck.
The RTC, via Order dated March 22, 2018, declared the subject truck confiscated in favor of the government.
A motion for reconsideration by the accused was denied on April 6, 2018.

Respondent filed an Omnibus Motion on May 9, 2018, to reopen the trial on the confiscation aspect, for intervention/third-party claim, and to release the subject truck.
Respondent asserted no knowledge of or participation in the crime and claimed ownership of the truck.
The RTC denied the motion, maintaining the confiscation order based on Section 77 of P.D. No. 705, which mandates confiscation of tools and equipment used in illegal forestry.

The CA nullified the RTC Order dated May 25, 2018, citing grave abuse of discretion and lack of jurisdiction on RTC’s part.
The CA distinguished administrative and judicial confiscation under P.D. No. 705 and held that Article 45 of the Revised Penal Code (RPC) is applicable and mandates the return of confiscated instruments if owned by a third party not liable for the offense.
The CA found that respondent was not impleaded in the case and proved ownership and non-involvement, warranting release of the truck.

Confiscation of vehicles used in illegal transport is a valid penalty under Section 68 of P.D. No. 705.
Being a special law, P.D. No. 705 should prevail over the general provisions of the RPC.

Respondent maintained the correctness of the CA ruling on due process and ownership considerations.

Whether the RTC had jurisdiction and authority to order confiscation of the subject truck used in transporting illegal forest products.
Whether Section 68 of P.D. No. 705, as a special law, overrides Article 45 of the RPC on the confiscation of instruments or tools used in the commission of a crime when claimed by a third party not liable for the offense.
Whether respondent’s right to due process was violated by the confiscation and denial of the opportunity to prove its ownership and non-participation in the crime.
Whether the CA erred in ordering outright the release of the subject truck without requiring formal presentation and admission of evidence in the trial court.