Case Digest (G.R. No. 165265)
Facts:
Maribel B. Jardeleza v. People of the Philippines, G.R. No. 165265, February 06, 2006, Supreme Court First Division, Callejo, Sr., J., writing for the Court.Petitioner Maribel B. Jardeleza, a Philippine Airlines flight stewardess, was charged by Information filed October 23, 1997 in the Regional Trial Court (RTC) of Pasay City, Branch 117, with unlawfully bringing into the Philippines, in a fraudulent and illegal manner, 20.1 kilograms of assorted gold jewelry, and with failing to declare the same in her Customs Declaration Form. The Information alleged she hid the jewelry inside a hanger bag and answered “No” when asked if she had anything to declare.
On February 28, 1997 customs personnel at Ninoy Aquino International Airport (NAIA), acting on an alert order to monitor a suspected courier on PAL Flight PR-502, examined petitioner’s hand-carried luggage. Customs Examiner Estelita Nario discovered three black leatherette envelopes inside a hanger bag; brochures were stacked in the envelopes but a bulge beneath the lining yielded wrapped packages containing gold jewelry when the lining was opened. A Held-Baggage Receipt was prepared, the items were turned over to the Customs In-Bound Room, and a seizure and detention order was later issued. A customs appraiser assessed the dutiable value at about P4.58 million and the assessed value at nearly P2.98 million.
At trial petitioner testified she was transporting the jewelry for a business associate, that she knew customs procedures for crew members, and that she had declared verbally to customs officers that she was carrying taxable jewelry and therefore requested the baggage be examined in the interview room to avoid the press. She also asserted that customs officers solicited bribes following the apprehension. The prosecution presented customs officers’ testimony and documentary exhibits; petitioner’s attempt to rely on memoranda and an investigator’s report reflecting an alleged earlier admission by her rested in part on hearsay and on a witness (SA I Antonio Fuentebella) who did not testify.
The RTC convicted petitioner on December 15, 2000 of violating Section 3601 of the Tariff and Customs Code (TCC) (smuggling), sentenced her to an indeterminate term of imprisonment (8 years & 1 day to 12 years), imposed a fine, and ordered forfeiture of the jewelry. On appeal, the Court of Appeals (CA) in CA-G.R. CR No. 25912 affirmed the conviction on September 8, 2004 and denied recons...(Pro-only)
Issues:
- Was petitioner properly charged and convicted under Section 3601 (smuggling) of the Tariff and Customs Code despite the Information’s reference to failure to declare under Section 2505?
- Did the prosecution prove petitioner’s guilt for smuggling beyond reasonable doubt under Section 3601, in relation to Sectio...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)