Case Summary (G.R. No. 241872)
Charges and Background
The Information filed on July 16, 2012, charged Nieto and Vicente with violating Section 68 (now Section 77) of the Revised Forestry Code of the Philippines due to their alleged possession and transportation of illegally cut timber without the necessary legal documentation. The incident occurred on July 15, 2012, in Laoag City, where the petitioners were found with a substantial quantity of forest products loaded in a truck owned by third parties. The total value of the seized timber was assessed at approximately PHP 442,402.00.
Prosecution's Evidence
The prosecution presented detailed evidence showing that on the specified date, a police officer stationed at a checkpoint received a tip regarding a truck transporting illegally cut logs. The truck, after being flagged down, failed to present proper documents related to the cargo despite showing a transport clearance in the name of an unrelated third party. Following the apprehension, an inventory revealed that the truck carried 409 pieces of Tanguile and White Lauan, along with 154 pieces of coco lumber, further corroborating the illegal activity.
Defense's Arguments
In their defense, Vicente and Nieto denied any wrongdoing, asserting that they were merely hired to drive the truck without knowledge of its illegal contents. Vicente stated that he had been misled by a neighbor about the purpose of the trip, while Nieto chose not to testify, indicating his intent to support Vicente's account. The defense contended that they had no intention to violate the law and highlighted alleged discrepancies in the lumber count as a basis for exoneration.
Ruling of the Regional Trial Court (RTC)
The RTC ruled against the petitioners, finding them guilty beyond reasonable doubt of the charges. The court emphasized that possession of the timber without the requisite documentation constituted a violation of the Revised Forestry Code, and Vicente and Nieto's claims of being misled by a third party were deemed insufficient to negate culpability.
Ruling of the Court of Appeals (CA)
The CA upheld the RTC's decision, stating that Vicente, as the driver, exerted control over the vehicle containing the illegal timber. The appellate court noted that mere possession of timber without legal documents is illegal, regardless of the claim of lack of malicious intent. The CA dismissed the defense's argument regarding discrepancies in the lumber inventory, attributing these inconsistencies to natural deterioration over time and affirmed the presence of illegal possession.
Petition to the Supreme Court
The petitioners filed a Motion for Reconsideration, which was consequently denied, leading to the current petition before the Supreme Court. They raised issues regarding their alleged possession of the timber and the applicability of certain defenses related to discrepancies in evidence.
Supreme Court's Analysis and Decision
The Supreme Court dismissed the petition, affirming the factual findings of both the RTC and the CA, which established that the petitioners were in possession of the tim
...continue readingCase Syllabus (G.R. No. 241872)
Case Background
- The case involves Mark Anthony Nieto and Filemon Vicente as petitioners against the People of the Philippines, stemming from a conviction for illegal possession of timber under the Revised Forestry Code.
- The petition seeks to reverse the Decision and Resolution of the Court of Appeals (CA), which affirmed the Regional Trial Court (RTC) ruling convicting the petitioners.
Legal Framework
- The offense in question is defined under Section 68 (now Section 77) of Presidential Decree No. 705, also known as the Revised Forestry Code of the Philippines, which penalizes the possession of timber or forest products without the requisite legal documentation.
- The nature of the offense is classified as malum prohibitum, meaning that criminal intent is not a necessary element; rather, the act itself constitutes the offense.
Factual Antecedents
- The Information filed on July 16, 2020, charged Nieto and Vicente with possession of illegal timber on July 15, 2012, in Laoag City.
- The accused were allegedly found with 409 pieces of Tanguile and White Lauan lumber, and 154 pieces of coco lumber, totaling a significant monetary value, while transporting them without proper documentation in a truck.
Prosecution's Case
- Evidence presented by the prosecution indicated that police officers at a checkpoint received a tip-off about a truck carrying illegally cut logs.
- Upon stopping the truck, the officers found that the documentation presented was insufficient, leading to the apprehension of both Nieto and Vicente.
- An inventory conducted by the Community Environment and Natural Resources Office (CENRO) confirmed the presence of illegal timber and assessed its total market valu