Case Digest (G.R. No. 152644)
Facts:
John Eric Loney, Steven Paul Reid and Pedro B. Hernandez v. People of the Philippines, G.R. No. 152644, February 10, 2006, Supreme Court Third Division, Carpio, J., writing for the Court.Petitioners — officers of Marcopper Mining Corporation (President/CEO, Senior Manager, Resident Manager for Mining Operations) — were criminally charged after millions of tons of mine tailings discharged from Marcopper’s Mt. Tapian pit on 24 March 1994, flowing into the Boac and Makalupnit rivers. In August 1996 the Department of Justice filed multiple Informations in the Municipal Trial Court (MTC) of Boac, Marinduque: for violation of PD 1067 (Water Code), PD 984 (National Pollution Control Decree), RA 7942 (Philippine Mining Act), and Article 365 of the Revised Penal Code (Reckless Imprudence Resulting in Damage to Property), with the various Informations docketed separately so that each Information charged one offense.
Petitioners moved to quash on grounds of duplicity (multiple offenses for a single act), that two petitioners were not yet officers when the incident occurred, and that the Informations contained legal excuses or defenses. The MTC (Judge Zoleta) initially deferred ruling but later, in a Consolidated Order (28 April 1997), quashed the PD 1067 and PD 984 Informations while retaining the RA 7942 and Article 365 charges; the court reasoned that the elements of the special laws were absorbed by the Philippine Mining Act in that case. Petitioners were arraigned and entered not guilty pleas on the retained charges.
Public respondent (the People) appealed the quashal to the Regional Trial Court (RTC), Branch 38, which consolidated that appeal with petitioners’ certiorari petition (raffled to Branch 94). In its Resolution of 20 March 1998, Branch 94 granted the People’s appeal, set aside the MTC’s quashal of PD 1067 and PD 984, and otherwise affirmed the Consolidated Order. Branch 94 held the offenses were distinct and that a single act can violate separate statutes when each requires proof of an element the others do not.
The Court of Appeals, in a Decision dated 5 November 2001 (a...(Subscriber-Only)
Issues:
- Whether the multiple Informations (PD 1067, PD 984, RA 7942, and Article 365 RPC) should be quashed as duplicative and reduced to a single prosecution for Reckless Imprudence Resulting in Damage to Property (Art. 365).
- Whether reinstating and maintaining the multiple national-law charges contravenes this Court’s ruling in People v. Relova concerning protecti...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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