Case Digest (G.R. No. 158150) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Jackson Padiernos y Quejada, Jackie Roxas y German, and Rolando Mesina y Javate (G.R. No. 181111, August 17, 2015), petitioners Jackson Padiernos y Quejada (“Padiernos”), Jackie Roxas y German (“Roxas”), and Rolando Mesina y Javate (“Mesina”) were charged as accessories to illegal possession of lumber under P.D. No. 705. On November 15, 2002, DENR and police officers discovered and seized 818 pieces of undocumented lumber loaded on a ten-wheeler truck (Plate No. TFZ-747) in Dingalan, Aurora. The lumber was unloaded and guarded at the police station, while the truck remained under DENR and police custody. The next day, November 16, 2002, petitioners, together with the truck owner Santiago Castillo and principal accused Eddie Gatdula, arrived to retrieve the truck. Santiago handed the keys to Mesina, who suddenly sped off toward Nueva Ecija, ignoring warning shots fired by police and cries for help from the DENROs. The Philippine Army intercepted t Case Digest (G.R. No. 158150) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Petitioners: Jackson Padiernos y Quejada, Jackie Roxas y German, and Rolando Mesina y Javate.
- Charged by Information in RTC, Branch 66, Baler, Aurora, as accessories to illegal possession of lumber under P.D. 705, for “taking and carrying away” a ten-wheeler truck (Plate No. TFZ-747) to prevent its use as evidence and avoid confiscation.
- Prosecution Evidence
- November 15, 2002 in Caragsacan, Dingalan, Aurora: DENR Officer Felimon Balico inspected a parked truck loaded with 818 pieces of lumber (10,253 board feet) without permits; reported to SPO4 Ramil Gamboa and SPO4 Romulo Derit. Lumber unloaded and kept under guard; truck remained parked under DENRO and police watch.
- November 16, 2002: Petitioners Padiernos, Roxas, and Mesina, with Santiago Castillo (owner) and others, agreed to move the truck to the police station. Mesina drove; petitioners and DENROs boarded; instead of station, vehicle sped toward Nueva Ecija. Police gave chase and fired warning shots; Philippine Army blocked road at Brgy. Bagting, Gabaldon, NE. Truck stopped; petitioners Padiernos and Roxas insulted DENROs; police recovered truck and returned to Dingalan.
- Defense Evidence
- Mesina and Roxas testified they were asked by Santiago to drive the truck to Cabanatuan, assured no problem existed; they only learned of its confiscation upon arrival.
- Padiernos testified he merely hitched a ride and did not hear police warnings or DENROs’ shouts due to noisy engine and broken mirrors; petitioners split ways after Army interception.
- Lower Courts’ Decisions
- RTC (Crim. Case No. 3122): Convicted petitioners as accessories to P.D. 705—finding common design, prior knowledge of illegal transport, credible prosecution witnesses, and rejection of petitioners’ denial.
- CA (CA-G.R. CR No. 28920): Affirmed RTC’s factual findings; treated truck as “instrument” under RPC Art. 19(2); held that, notwithstanding mala prohibita nature of P.D. 705, petitioners’ knowledge sufficed; modified penalties.
Issues:
- Accessory Liability under P.D. 705 and RPC Art. 19(2)
- Whether petitioners can be held accessories for illegal possession of lumber when they took the truck after discovery and confiscation of the lumber.
- Whether their acts satisfy the element of preventing discovery of the crime as required by Art. 19(2).
- Alternative Criminal Liability under P.D. 1829
- Whether petitioners’ act of taking and carrying away the truck constitutes obstruction of justice under Section 1(b) of P.D. 1829.
- Whether the prosecution proved knowledge, intent, and suppression of evidence elements.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)