Case Summary (G.R. No. 180597)
Applicable Law
The governing legal provisions for this case include Section 2203 and Section 3612 of the Tariff and Customs Code. Specifically, Section 2203 delineates the authorities permitted to conduct searches, seizures, and arrests under customs laws, while Section 3612 specifies the penalties for violations of the Tariff and Customs laws and regulations.
Facts of the Case
On October 18, 2005, the petitioners were charged with taking advantage of their positions as public officers to flag down container vans without proper authority. The evidence presented by the prosecution included testimonies from other law enforcement personnel and a customs broker, indicating that the petitioners had no written authority from the Bureau of Customs to conduct the search. The petitioners claimed to have acted on an internal directive and were not physically involved in the search or seizure of items in the vans.
Ruling of the Sandiganbayan
The Sandiganbayan convicted the petitioners, stating that they lacked the required written authority to conduct searches or seizures as specified in the Tariff and Customs Code. The court emphasized that the authority to enforce customs law resides exclusively with the Bureau of Customs and cannot be exercised arbitrarily by PNP members. The court found the petitioners guilty and imposed penalties including a year of imprisonment and disqualification from holding public office for ten years.
Petitioners' Arguments
On appeal, the petitioners argued that they did not conduct any searches or seizures, asserting that they merely flagged down the trucks and observed the Customs Police conducting the searches the following day. They contended that as active police officers, they had the authority to monitor situations concerning potential smuggling and therefore did not require prior authority from the Collector of Customs for the actions taken.
The Court's Ruling
The Supreme Court found merit in the petitioners' arguments, reversing the Sandiganbayan’s decision and acquitting them of the charges. The Court noted that the prosecution failed to prove beyond reasonable doubt that the petitioners had engaged in searches, seizures, or arrests as defined under the Tariff and Customs Code. Testimonies corroborated that the actual search was carried out by customs officials and not by the petitioners. Furthermore, the act of merely flagging down the container vans was
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Case Overview
- This case involves an appeal by certiorari under Rule 45 to set aside the August 16, 2007 Decision of the Sandiganbayan.
- Petitioners Raul Basilio D. Boac, Ramon B. Golong, Cesar F. Beltran, and Roger A. Basadre were found guilty of violating Section 2203 of the Tariff and Customs Code.
- The motion for reconsideration was denied by the Sandiganbayan on November 14, 2007.
Facts of the Case
- The petitioners are members of the Philippine National Police (PNP)-Criminal Investigation and Detection Group (CIDG) and hold various ranks.
- They were charged with violating Section 2203 in relation to Section 3612 of the Tariff and Customs Code for allegedly flagging down, searching, and seizing three container vans without lawful authority.
- The events transpired in Cagayan de Oro City, where the petitioners flagged down container vans consigned to Kakiage Surplus, purportedly on the orders of Boac, without coordination with the Bureau of Customs (BOC).
- Witnesses, including Atty. Lourdes V. Mangaoang (Customs District Collector) and Dario C. Amolata (customs broker), testified regarding the lack of written authority for the petitioners to conduct searches.
- The actual search of the container vans took