Title
PadierNo.y Quejada vs. People
Case
G.R. No. 181111
Decision Date
Aug 17, 2015
Petitioners took a truck loaded with illegal lumber to suppress evidence, acquitted as accessories but convicted for obstruction of justice under P.D. 1829.

Case Summary (G.R. No. 181111)

Key Dates and Procedural Posture

  • Factual events: November 15–16, 2002 (seizure of lumber and subsequent taking of the truck).
  • Trial court: Regional Trial Court (Branch 66, Baler, Aurora) convicted the petitioners as accessories to violation of P.D. No. 705.
  • Intermediate appellate court: Court of Appeals affirmed with modification.
  • Supreme Court: Petition for review on certiorari filed; Supreme Court granted the petition in part and modified the conviction and penalty (see analysis below).
  • Applicable constitutional framework: 1987 Philippine Constitution governs the proceedings and appellate review.

Applicable Statutes and Legal Concepts

  • Presidential Decree No. 705 (Forestry Reform Code of the Philippines) — criminalizes unlawful possession/transport of lumber and authorizes confiscation/forfeiture of instruments used in the crime.
  • Article 19, paragraph 2, Revised Penal Code — defines “accessories” as those who, with knowledge of the commission of the crime and without prior participation, take part subsequent to its commission by concealing or destroying the body of the crime or its instruments to prevent discovery.
  • Presidential Decree No. 1829, Section 1(b) — penalizes obstruction of apprehension and prosecution; specifically proscribes altering, destroying, suppressing, or concealing any object with intent to impair its availability or admissibility as evidence in criminal investigations or proceedings.
  • Evidentiary and appellate principles: the factual allegations in the Information determine the nature of the offense; appeal opens the entire case for review and permits the appellate court to correct errors even if not raised.

Facts — Prosecution Evidence

  • On November 15, 2002, DENR officer Balico approached a truck loaded with lumber parked on a national highway in Dingalan; driver Frederico and helper Mostera could not produce supporting transport documents.
  • DENR reported the matter to police; lumber was unloaded and transferred to police custody, and the truck was left guarded at the highway by DENROs and some police officers overnight.
  • On November 16, 2002, the truck owner Santiago and others including petitioners Mesina, Roxas, and Padiernos arrived. Santiago purportedly agreed with DENR and police to bring the truck to the police station, handed truck key to Mesina, and Mesina started the truck with petitioners aboard. DENROs rode at the back; two policemen escorted on a motorcycle.
  • Instead of proceeding to the police station, Mesina accelerated toward Nueva Ecija. The motorcycle escorts chased and fired warning shots; the truck continued until intercepted by the Philippine Army at Brgy. Bagting.
  • At interception, petitioners’ conduct included profanity directed at DENROs and resistance; police recovered the truck and returned it to Dingalan.

Facts — Defense Evidence

  • Petitioners testified they were asked by Santiago to bring the truck to Cabanatuan/Cabanatuan City; they initially resisted but agreed after Santiago assured them the matter was settled.
  • Petitioners denied hearing shouts, tapping, or warning shots due to alleged running engine noise and broken windows; they claimed no intent to suppress evidence and asserted they did not know the DENROs were attempting to secure the truck at the time.
  • Mesina and Roxas admitted prior knowledge that the truck had previously been involved in illegal activity but claimed reliance on Santiago’s assurances that the problem had been resolved.

RTC Decision (Trial Court)

  • The RTC found petitioners guilty as accessories to violation of P.D. No. 705. The court concluded petitioners conspired and had a common design to take away the truck to prevent its use as evidence and avoid its forfeiture.
  • The RTC credited prosecution witnesses as categorical, straightforward, and consistent; it disbelieved petitioners’ denials based on testimony, petitioners’ admissions, and ocular inspection of the truck (which rebutted claims that external sounds could not be heard).
  • The RTC relied on petitioners’ familiarity with local illegal transport practices, their association with Santiago, and Padiernos’s hostile remarks to DENROs as proof of knowledge and intent.

Court of Appeals Ruling

  • The Court of Appeals affirmed the RTC’s factual findings but modified the penalties. It characterized the truck as an “instrument” of the offense under Article 19(2) RPC because the truck formed the essential link to discovery and presentation of the lumber as evidence for P.D. No. 705.
  • The CA held that because P.D. No. 705 is mala prohibita, proof of intent, motive, or knowledge need not be established for guilt, but it also found that on the record petitioners had knowledge and thus rejected their denial defenses.
  • The CA highlighted petitioners’ close associations with Santiago and each other as supporting conspiracy to take the truck.

Issues Presented to the Supreme Court

  • Whether petitioners are properly convicted as accessories to the crime of illegal possession/transport of lumber under P.D. No. 705, consistent with Article 19(2) RPC.
  • Alternatively, whether the factual allegations and proof more appropriately establish another offense, specifically obstruction of justice under Section 1(b) of P.D. No. 1829.

Supreme Court Legal Analysis — Role of the Information and Charge

  • The Court reiterated the controlling principle that the factual allegations in the Information—not the technical label assigned by the prosecutor—determine the nature of the offense charged and the acts the accused must defend. The Information in this case alleged that the petitioners “took and carried away” the truck “so it could not be used as evidence and avoid confiscation and forfeiture.”
  • The Court examined Article 19(2) RPC’s definition of accessory liability, emphasizing that to convict as an accessory the acts must be committed with the specific purpose of preventing the discovery of the crime and must occur subsequent to the commission of that crime.

Supreme Court Analysis — Why Accessory Liability under Article 19(2) RPC Does Not Fit

  • The Supreme Court found a legal mismatch: by the time petitioners took the truck (November 16, 2002), the illegal possession/transport under P.D. No. 705 had already been discovered and the lumber had been unloaded and placed in police custody on November 15, 2002.
  • Because the crime punishable under P.D. No. 705 had already been discovered and evidence (the lumber) was already in custody, Article 19(2)’s conception of an accessory—who conceals instruments or evidence to prevent discovery—did not align with the factual conduct alleged and proved. The offense of being an accessory presupposes that concealment precedes or prevents discovery; here discovery had occurred prior to the taking of the truck.

Supreme Court Analysis — Obstruction of Justice under P.D. No. 1829, Section 1(b)

  • The Court identified that the factual allegations in the Information correspond to the elements of obstruction of justice under Section 1(b) of P.D. No. 1829: alteration, destruction, suppression or concealment of an object (the truck) with intent to impair its availability or admissibility as evidence in criminal investigations or proceedings.
  • The Supreme Court found the truck to be indispensable evidence and an essential link in proving the illegal transport/possession of the lumber because transportation permits and other documentary links necessarily involve the truck as a means and connection to the alleged offenders.
  • The Court concluded the petitioners deliberately suppressed the truck. It relied on admissions and testimonies establishing petitioners’ knowledge of the truck’s involvement in illegal activity, their association with Santiago, Padiernos’s hostile remarks demonstrating

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