G.R. No. 136142 - People vs. Telen

On October 29, 1993, police officers—including Police Station Commander Alejandro Rojas and SPO1 Necitas Bacala—observed an Isuzu cargo truck transporting pieces of lumber in Maasin, Southern Leyte.
The police, suspecting that the cargo consisted of illegally cut lumber, initiated a chase and subsequently apprehended the truck in Barangay Soro-soro, where the driver, Benito Genol, was ordered to stop.

Upon inspection at the scene, Forest Ranger Romeo Galola, together with his supervisor Sulpicio Saguing, verified that the cargo comprised 41 pieces of Dita lumber and 10 pieces of Antipolo lumber totaling 1,560.16 board feet.
SPO1 Bacala issued a seizure receipt for the lumber and the accompanying Isuzu cargo truck (Plate No. HAF 628), which was then turned over to SPO3 Daniel Lasala and thereafter to the Community Environment and Natural Resources Office (CENRO) in Maasin.

Pastor Telen, owner of the lumber, was charged with violating Section 68 of Presidential Decree No. 705 (Revised Forestry Code) for unlawfully possessing lumber without the legally required DENR documents.
Telen alleged that he had secured verbal permission from Boy Leonor, Officer-in-Charge of CENRO, to cut the lumber from his mother’s property, with the understanding that no written permit was necessary for soft lumber (Dita and Antipolo) intended for renovating his house.
Despite his claim, no corroborative testimony from Boy Leonor was provided during trial, rendering the verbal permission allegation self-serving.

Alongside Telen, Alfonso Dator and Benito Genol were implicated in the incident. Dator, the accounting manager of SLEFAICO, Inc., and Genol, the driver of the company’s truck, played roles in facilitating the transport of the lumber.
Testimonies from Dator and Genol detailed the arrangements made for hiring the truck and transporting the lumber, as well as the circumstances under which the confiscation occurred.

Documents such as the DENR-CENRO transmittal letter estimated the lumber’s value at ₱23,500, a figure mentioned in the Information though later challenged for evidentiary insufficiency.
The case record reflects that following the apprehension, Telen and the co-accused were arraigned, and while Telen pleaded "not guilty," the trial proceeded on the merits of the violation of forest laws.
Law enforcement and administrative procedures, including the seizure and subsequent transfer of the lumber and truck to government custody, were executed as per the established protocols.

Whether Pastor Telen was rightfully convicted beyond reasonable doubt for violating Section 68 of Presidential Decree No. 705 by possessing lumber without the required legal documents, notwithstanding his claim of having secured verbal permission.

Whether the imposition of the extremely severe penalty of reclusion perpetua (which is two degrees higher than prision mayor) was warranted, or if it constituted an error given the nature of the offense and the applicable provisions of the Revised Penal Code and related jurisprudence.

Whether the failure to prove the estimated value of the confiscated lumber (₱23,500) during trial should affect the imposition of the penalty, especially since penalty is not an essential element of the offense.