Case Digest (G.R. No. 214647)
Facts:
- The case involves Edwin Talabis (petitioner) and the People of the Philippines (respondent).
- Events occurred on December 4, 2005, in Sinto Bangao, Buguias, Benguet.
- Petitioner and co-accused Arsebino Talabis were charged with violating Section 68 of Presidential Decree No. 705 (Revised Forestry Code of the Philippines).
- The complaint was filed by Leonora Edoc and Rhoda E. Bay-An before Provincial Prosecutor Felix T. Cabading.
- The Information alleged conspiracy to cut, collect, and gather pine trees without a lawful permit, totaling 3.1464 cubic meters valued at P22,496.76.
- Witnesses Eric Lanta-an and Raymundo Abuyog heard a chainsaw and saw the accused cutting trees.
- Leonora and her husband discovered the missing trees and confronted the accused, who could not provide a cutting permit.
- Forester Cesar Kitayan verified the illegal cutting, leading to the complaint.
- The Regional Trial Court (RTC) found both accused guilty and sentenced them to imprisonment.
- The Court of Appeals (CA) affirmed the RTC's ruling with modifications on the penalty.
- The petitioner sought further review from the Supreme Court after the CA denied his motion for reconsideration.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the RTC did acquire jurisdiction over the case, affirming the CA's decision.
- The Court held that the petitioner was not entitled t...(Unlock)
Ratio:
- The Supreme Court explained that the RTC's jurisdiction was valid even with a complaint from private individuals, as Section 80 of PD 705 permits such actions when the offense is not witnessed by a forest officer.
- The Court referenced Merida v. People, establishing that private individuals can initiate complaints for violations of PD 705.
- Procedural rules do not prevent private individuals from filing complaints with the Pro...continue reading
Case Digest (G.R. No. 214647)
Facts:
The case involves Edwin Talabis (petitioner) and the People of the Philippines (respondent). The events leading to the case occurred on December 4, 2005, in Sinto Bangao, Buguias, Benguet. Petitioner and his co-accused, Arsebino Talabis, were charged with violating Section 68 of Presidential Decree No. 705, also known as the Revised Forestry Code of the Philippines. The complaint was initiated by Leonora Edoc and Rhoda E. Bay-An, who filed a Joint Affidavit-Complaint against the accused before the Office of Provincial Prosecutor Felix T. Cabading. The Information alleged that the accused conspired to cut, collect, and gather pine trees without any lawful permit, resulting in a total volume of 3.1464 cubic meters valued at P22,496.76.
During the trial, it was established that on the day of the incident, while gardening, witnesses Eric Lanta-an and Raymundo Abuyog heard a power chainsaw and observed four men, including petitioner and Arsebino, cutting down pine trees. Leonora and her husband later discovered the missing trees and confronted the accused, who failed to provide proof of a cutting permit. A forester, Cesar Kitayan, was informed and subsequently verified the illegal cutting, leading to the filing of the complaint. The Regional Trial Court (RTC) found both accused guilty and sentenced them to impri...