Title
Sea Lion Fishing Corp. vs People
Case
G.R. No. 172678
Decision Date
Mar 23, 2011
Sea Lion Fishing Corporation fails to prove ownership of the confiscated fishing vessel, resulting in its forfeiture to the government in a case involving poaching in Balabac, Palawan.
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Case Digest (G.R. No. 172678)

Facts:

  • Parties Involved: Sea Lion Fishing Corporation vs. People of the Philippines.
  • Incident: Government confiscated the petitioner's fishing vessel, F/V Sea Lion.
  • Location: Mangsee Island, Balabac, Palawan.
  • Discovery: Vessel anchored three nautical miles northwest of Mangsee Island with fishing paraphernalia.
  • Apprehension: Vessel's captain (Filipino), three Filipino crew members, and three Chinese crew members arrested; 17 Chinese fishermen aboard the vessel also detained.
  • Charges: Violations of Sections 97 and 90 of RA 8550, and Sections 27 (a) and (f) of RA 9147.
  • Prosecutor's Actions: Some charges dismissed; probable cause against 17 Chinese fishermen, who were charged in court.
  • Petitioner's Actions: Filed an Urgent Motion for Release of Evidence claiming ownership of the vessel; failed to comply with conditions for release.
  • RTC Decision: Found 17 Chinese fishermen guilty of lesser offenses; ordered confiscation of F/V Sea Lion.
  • Subsequent Actions: Petition for Certiorari and Mandamus filed with CA; CA denied petition; Petition for Review on Certiorari filed with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. Petition Denied: Supreme Court denied the petition and affirmed the CA's decision, upholding the confiscation of the F/V Sea Lion.
  2. Ownership Evidence: Petitioner failed to provide sufficient evidence to support its claim of ownership over the vessel....(Unlock)

Ratio:

  • Incorrect Remedy: Petitioner pursued an incorrect remedy by filing a Petition for Certiorari under Rule 65 instead of an appeal.
  • Jurisdiction: CA found no jurisdictional error or grave abuse of discretion by the trial court, which had the authority to seize the vessel.
  • Lack of Evidence: Petitioner did not present evidence to support its ownership claim; only a request for release based on alleged ownership, which was unsubstantiated.
  • Compliance Failure: Petitioner failed to comply with conditions set by the Provincial Prosecutor for the vessel's release and did not intervene during judicial proceedings.
  • New Trial/Reopening: Petitioner should have moved for a new trial or reopening of the trial on the confiscation aspect rather than filing a motion for reconsideration.
  • Due Process Opportunity: Court found that petitioner was given ample opportunity to be heard but failed to act accordingly.
  • Proper Order: Trial court's order to c...continue reading

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