Case Summary (G.R. No. 152160)

Case Overview

The decision pertains to a Petition for Review under Rule 45 of the Rules of Court filed by petitioner Virgilio Bon against the People of the Philippines. The petition seeks to nullify the Court of Appeals (CA) Decision dated August 22, 2001, affirming Bon's conviction for illegal cutting of trees, and its Resolution dated February 15, 2002, which denied his motion for reconsideration.

Legal Principles Involved

Hearsay Testimony

• Legal Principle: Testimonies regarding statements made by a party can be admissible as evidence, not to prove the truth of the statement but to establish that it was made.
• Key Definitions:
  • Hearsay: Evidence not based on a witness's personal knowledge but rather on what someone else said.
• Requirements:
  • Must be based on the witness's personal perception.
  • The statement's admissibility rests on whether it is relevant to a fact in issue.

Circumstantial Evidence

• Legal Principle: Circumstantial evidence can suffice for conviction if it creates an unbroken chain of facts leading to a reasonable conclusion of guilt.
• Important Requirements:
  • More than one circumstance must be proven.
  • The circumstances must be sufficient to support a conviction beyond a reasonable doubt.

Case Background

• Charges: Virgilio Bon, Alejandro Jeniebre, Jr., and Rosalio Bon were charged with violating Section 68 of PD 705 (Revised Forestry Code) for illegal cutting of trees without the necessary permits.
• Relevant Actions:
  • On February 12, 1990, witnesses, including Barangay Tanod Julian Lascano, discovered tree stumps on the land owned by Teresita Dangalan-Mendoza, who alleged illegal cutting.
  • Virgilio Bon admitted to ordering the cutting of the trees during the investigation.

Court Rulings

Trial Court and Court of Appeals Findings

• The trial court convicted Virgilio Bon and Jeniebre, while Rosalio Bon was acquitted.
• The Court of Appeals upheld the conviction, emphasizing:
  • The credibility of prosecution witnesses.
  • The sufficiency of circumstantial evidence.

Issues Presented

1. Admissibility of Extrajudicial Admissions: Petitioner argues that testimonies regarding his admissions are hearsay and thus inadmissible.
2. Credibility of Prosecution Witnesses: Petitioner questions the trustworthiness of the witnesses who testified against him.

Court's Ruling

• First Issue: The Court determined that the testimonies were admissible as they were based on personal knowledge, and the statements were relevant to the case.
• Second Issue: The Court affirmed the lower court's credibility assessments and found sufficient circumstantial evidence to convict Bon.

Penalty

• The appellate court modified the penalty to an indeterminate sentence of ten years of prision mayor as minimum to fourteen years and eight months of reclusion temporal as maximum.
• The Court ultimately decided to adopt the trial court's original indeterminate sentence of seven years, four months, and one day of prision mayor as minimum to eleven years, six months, and twenty-one days of prision mayor as maximum.

Key Takeaways

• Testimonies can be admissible as evidence even if they are considered hearsay, provided the

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Case Syllabus (G.R. No. 152160)

Case Background

• This case involves a Petition for Review under Rule 45 of the Rules of Court, filed by petitioner Virgilio Bon to nullify the August 22, 2001 Decision and the February 15, 2002 Resolution of the Court of Appeals (CA).
• The CA affirmed the trial court's conviction of Virgilio Bon for illegal cutting of trees while acquitting co-accused Alejandro Jeniebre, Jr.
• The dispositive part of the CA Decision modified the penalty against Bon, sentencing him to an indeterminate penalty of imprisonment ranging from ten years of prision mayor as minimum to fourteen years and eight months of reclusion temporal as maximum.

Antecedents of the Case

• Virgilio Bon, Alejandro Jeniebre, Jr., and Rosalio Bon were charged under Section 68 of PD 705 (Revised Forestry Code) for cutting trees without consent from the owner, Teresita Dangalan-Mendoza.
• The Information alleged that the accused conspired to cut and manufacture into lumber several trees, causing damages amounting to approximately P25,000.
• Upon arraignment, all accused pleaded not guilty, and the trial ensued with testimonies from various prosecution witnesses including Teresita Dangalan-Mendoza, barangay tanods, and others.

Prosecution's Evidence

• Teresita Dangalan-Mendoza, the landowner, reported that trees were being stolen from her land, leading to an investigation.
• Several witnesses testified that they discovered stumps of trees on the property, and photographs were taken.
• Virgilio Bon admitted to having ordered the cutting of the trees, which was corroborated by Oscar Narvaez, who testified that he sawed the trees upon instruction from Jeniebre.
• The prosecution presented circumstantial evidence linking Bon to the crime, emphasizing his admissions and the absence of any permits f

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