Case Summary (G.R. No. 181111)
Petitioners and Respondent
Petitioners: Jackson Padiernos, Jackie Roxas, Rolando Mesina
Respondent: People of the Philippines
Key Dates
– November 15, 2002: Seizure and custody of undocumented lumber on truck TFZ-747 in Dingalan, Aurora
– November 16, 2002: Petitioners allegedly took and drove the truck to Nueva Ecija
– May 10, 2007: CA decision affirming RTC conviction with modified penalties
– August 17, 2015: Supreme Court decision
Applicable Law
– Presidential Decree No. 705 (Forestry Reform Code)
– Article 19, paragraphs 1 and 2, Revised Penal Code (RP C) on principals, accomplices, and accessories
– Presidential Decree No. 1829, Section 1(b) on obstruction of justice
Prosecution’s Factual Findings
On November 15, 2002, DENR and police officers discovered 818 pieces of unpermitted lumber on a Denver‐guarded ten-wheeler truck (Plate No. TFZ-747). The lumber was unloaded and placed in custody, while the truck remained guarded overnight. On the afternoon of November 16, various accused, including petitioners, arrived. Santiago Castillo (owner) handed keys to Mesina, who drove off toward Nueva Ecija despite DENR and police escorts’ warnings and warning shots. The truck was eventually intercepted by the Philippine Army and returned to police custody. Witnesses testified that petitioners knew the truck was evidence of illegal forestry activity.
Defense’s Version of Events
Mesina and Roxas testified that Santiago specifically requested transport of the truck to Cabanatuan City and assured them he had settled any legal issues. Roxas initially refused but agreed after assurances. Padiernos testified he merely sought a ride and only learned of the truck’s status on arrival. All three denied hearing any warnings or realizing the truck was under official custody until stopped by the Army. They argued lack of intent to impair its evidentiary value.
RTC Findings and Ruling
The RTC found the prosecution witnesses credible, noting consistency and lack of improper motive. It concluded petitioners shared a common design with Santiago to remove the truck, demonstrated by their admissions of knowing the truck’s prior confiscation and by Padiernos’s derogatory remarks toward DENR officers. The RTC convicted them as accessories under PD 705 and imposed penalties corresponding to accessory liability.
CA Findings and Modification
The CA adopted the RTC’s factual findings but viewed the truck as an “instrument” of crime under Article 19(2) of the RPC. It held that petitioners’ knowledge of the truck’s involvement sufficed for accessory liability even though PD 705 is a mala prohibita offense. The CA modified the penalties but affirmed guilt as accessories to violation of PD 705.
Parties’ Contentions on Appeal
Petitioners argued they could not be accessories because the offense had already been discovered and the truck was in official custody when they drove it away. They maintained Article 19(2) only punishes acts preventing discovery. The People contended that petitioners acted to frustrate evidence presentation and thereby obstruct investigation.
Supreme Court Analysis on Accessory Liability
The Court reiterated that the Information’s factual allegations—not the prosecutor’s label—define the offense. Article 19(2) punishes post-crime concealment to prevent discovery of an undiscovered crime; here, the illegal possession was already discovered, and the lumber and truck were already under custod
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Facts of the Case
- On November 15, 2002 at around 6:00 a.m., DENR Officer Felimon Balico encountered a ten-wheeler truck (Plate No. TFZ-747, “JEROME”) parked on a national highway in Caragsacan, Dingalan, Aurora, loaded with 818 pieces of undocumented lumber (10,253 board feet, valued at ₱133,289.00).
- The truck driver and helper failed to produce any permit, license, or supporting documents; Balico reported to SPO4 Ramil Gamboa and SPO4 Romulo Derit, who, together with DENROs Balico, Tarcila Vivero, and Rodolfo Tumagan, guarded the truck.
- The lumber was transferred to the police station on November 15–16, 2002; the truck remained at the highway under guard.
- On November 16, 2002, Santiago Castillo (owner), Rolando Mesina, Jackie Roxas, Jackson Padiernos, and Eddie Gatdula arrived. Santiago handed the truck key to Mesina; Padiernos inquired about the lumber.
- Mesina started the engine, petitioners and DENROs boarded; motorcycle escorts Mendoza and Fajardo followed. Instead of proceeding to the station, Mesina drove toward Nueva Ecija, leaving escorts behind.
- The police fired warning shots; the Philippine Army later blocked the road at Brgy. Bagting, Nueva Ecija. The truck was recovered; Padiernos insulted the DENROs at the scene.
Procedural History
- RTC Branch 66, Baler, Aurora (Criminal Case No. 3122): Convicted Padiernos, Mesina, and Roxas as accessories to illegal possession of lumber under P.D. 705.
- Court of Appeals (CA-G.R. CR No. 28920): May 10, 2007 decision affirmed the RTC’s findings, modified the penalty; December 20, 2007 resolution denied reconsideration.
- Supreme Court: Petition for review on certiorari filed by petitioners; G.R. No. 181111 docketed.
Issue
- Whether petitioners can be held liable as accessories under Article 19, paragraph 2 of the RPC for taking and carrying away the truck after its confiscation.
- Whether the factual allegations in the Information better constitute the crime of obstruction of justice under Section 1(b) of P.D. 1829.
Prosecution Evidence
- Testimony of DENRO Balico: No transportation permits; group guarded lum