Case Summary (G.R. No. 165265)
Facts of the Case
Jardeleza was charged with violating the Tariff and Customs Code of the Philippines for allegedly smuggling 20.1 kilograms of assorted gold jewelry valued at PHP 7,562,231.50 into the Philippines without declaring it to Customs authorities. The charge originated from an incident that occurred on February 28, 1997, at the Ninoy Aquino International Airport (NAIA), where customs officers discovered the jewelry hidden in her baggage.
Case for the Prosecution
The prosecution's case was based on an alert order issued by the Customs Police to monitor a suspected jewelry carrier from Singapore. When Jardeleza arrived, she presented her luggage for inspection but denied having anything to declare. Customs Examiner Estelita Nario found the jewelry concealed in leatherette envelopes hidden within her hanger bag. Nario followed proper inspection protocols, which included taking photographs and recording the items found. Subsequently, several customs officials became involved, and a report was drafted recommending the confiscation of the jewelry.
Case for the Accused
In her defense, Jardeleza testified about her long tenure with Philippine Airlines, her planned jewelry business, and her understanding of customs procedures. She claimed that her failure to declare the jewelry was because it was numerous and she could not fit it into the declaration form. She also alleged that she informed customs officials of her taxable items, asserting she requested an inspection in a private area to avoid media attention, contradicting the assertion of intentional concealment.
Ruling of the Trial Court
On December 15, 2000, the RTC convicted Jardeleza, holding that she had committed the offense of smuggling under Section 3601 of the TCC. The court emphasized her failure to declare the jewelry and the fraudulent manner in which it was concealed, sentencing her to imprisonment and imposing a fine.
Proceedings in the Court of Appeals
Jardeleza appealed the RTC decision, contending that the court erred in convicting her under Section 3601 rather than Section 2505, asserting that the facts did not constitute a smuggling offense. The CA upheld the RTC's ruling, corroborating that Jardeleza's actions constituted actual fraud, affirming her conviction, and emphasizing the sufficiency of evidence presented by the prosecution.
Ruling of the Supreme Court
The Supreme Court upheld the lower courts' decisions, rejecting Jardeleza's arguments regarding her intent and the applicable sections of the TCC. The Court determined that the evidence sufficiently demonstrated her possession and concealment of the jewelry, constituting smuggling under Section 3601. The Court clarified the relationship between Sections 2505 and 3601 of the TCC, emphasizing that while Section 2505 addresses procedural violations with civil implications, Section
...continue readingCase Syllabus (G.R. No. 165265)
Background of the Case
- This case involves a petition for review of the Decision of the Court of Appeals (CA) affirming the Regional Trial Court (RTC) conviction of Maribel B. Jardeleza for violating the Tariff and Customs Code (TCC) of the Philippines.
- The indictment against Jardeleza was filed on October 23, 1997, charging her with unlawfully importing 20.1 kilograms of assorted gold jewelry worth approximately ₱7,562,231.50 into the Philippines without declaration.
Antecedents of the Case
- The incident occurred on February 28, 1997, at the Ninoy Aquino International Airport (NAIA) when Jardeleza, a flight stewardess, attempted to bring in the jewelry hidden in her luggage.
- The prosecution accused Jardeleza of hiding the jewelry in a hanger bag and failing to declare it on the Customs Declaration Form.
- Upon questioning by Customs officials, she denied carrying any items to declare.
Prosecution's Case
- The prosecution's case relied on the testimonies of Customs officials, particularly Customs Examiner Estelita Nario, who discovered the jewelry during a routine inspection.
- Nario, upon inspecting Jardeleza's bags, found the jewelry hidden in leatherette envelopes with false decoy items (Bosch spark plug brochures).
- The prosecution’s evidence established that Jardeleza had actual possession of the jewelry and had intentionally concealed it, thereby committing fra