G.R. No. 181111 - PadierNo.y Quejada vs. People

Case Summary (G.R. No. 181111)

Factual Background

On November 15, 2002, DENR personnel found a ten-wheeler truck bearing the name "JEROME" and Plate No. TFZ-747 loaded with lumber parked along the national highway in Dingalan, Aurora. The truck driver and helper failed to produce transportation documents for the lumber. The DENR officers and accompanying police guarded the truck and decided to transfer the load to the police station; the lumber was transferred on November 15–16, 2002, while the truck remained parked under guard. On November 16, 2002, Santiago Castillo and several companions arrived; Santiago purportedly owned the truck. Santiago handed the truck keys to Rolando Mesina y Javate, who drove the truck with Jackson Padiernos y Quejada and Jackie Roxas y German aboard. The DENR officers rode at the rear. Instead of proceeding to the police station, the truck sped toward Nueva Ecija. Two police escorts pursued and fired warning shots. The Philippine Army intercepted and stopped the truck at Barangay Bagting, Gabaldon, Nueva Ecija, whereupon the DENR officers and police recovered custody of the truck and the petitioners alighted.

Prosecution’s Evidence

The prosecution presented testimony from DENR and police officers describing discovery of undocumented lumber and subsequent guarding of the truck. The witnesses testified that the petitioners participated in taking the truck on November 16 and that the truck was driven away at high speed despite warnings, leaving behind police escorts. Witnesses recounted that petitioners displayed knowledge of the truck’s status as involved in illegal transport of lumber. One DENR witness testified that the petitioners took the truck so that it could not be used as evidence and to avoid its confiscation and forfeiture.

Defense Evidence

The petitioners testified that they rode with Santiago after he assured them that any problem with the truck had been settled. Mesina admitted initial reluctance because the truck had been previously implicated in illegal activities but stated he agreed to drive at Santiago’s insistence. Roxas testified that he likewise only agreed after being assured there was no problem. Padiernos testified he merely sought a ride to Cabanatuan City and only learned of the truck’s location upon arrival. The petitioners denied hearing any shouts or warning shots and maintained they had no intent to suppress evidence.

Trial Court Ruling

The RTC convicted Padiernos, Mesina, and Roxas as accessories to the crime of illegal possession of lumber in violation of P.D. No. 705. The trial court found the prosecution witnesses credible and concluded that the petitioners had a common design to take away the truck to prevent its use as evidence and to avoid confiscation. The RTC rejected the petitioners’ denials and credited its ocular inspection of the truck to refute their claim that they could not have heard warnings.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC’s factual findings but modified the penalty. The CA treated the truck as an “instrument” of the offense under Article 19, paragraph 2, Revised Penal Code and sustained conviction as accessories. The CA observed that the offense under P.D. No. 705 is mala prohibita and therefore need not establish intent, and it concluded that the petitioners’ admissions and association with Santiago showed awareness of the truck’s involvement in illegal activities.

Parties’ Contentions on Appeal

The petitioners argued that they could not be convicted as accessories under Article 19 because the crime punishable under P.D. No. 705 had already been discovered and the truck placed under custody when they took it; Article 19 punishes acts intended to prevent discovery of an undiscovered crime. The People of the Philippines countered that the petitioners acted to frustrate the investigation and prosecution by depriving authorities of a vital link to the lumber and by enabling contrived transportation documents to exculpate the principals.

Issues Presented to the Supreme Court

Whether the petitioners were properly convicted as accessories under Article 19, paragraph 2, Revised Penal Code for taking away the truck; and whether the factual allegations proved at trial instead constituted obstruction of justice under P.D. No. 1829, Section 1(b).

Supreme Court’s Ruling

The Supreme Court reversed the CA’s judgment insofar as it sustained conviction as accessories under Article 19. The Court held that the discovery of the illegal possession and the confiscation of the lumber and truck occurred on November 15, 2002, prior to the petitioners’ taking of the truck on November 16, 2002. Because the offense under Article 19, paragraph 2 punishes concealment or destruction committed to prevent the discovery of a crime, the petitioners’ acts could not constitute accessories to the already discovered offense. The Court nevertheless found the petitioners guilty of obstruction of justice under Section 1(b) of P.D. No. 1829 for altering, destroying, suppressing, or concealing an object with intent to impair its availability or admissibility as evidence in a criminal investigation or official proceeding.

Legal Basis and Reasoning

The Court reiterated the principle that the allegations in the Information determine the factual charge and that an appellate court may correct errors and consider the actual crime proved in the record (citing People v. Llaguno, et al., and People v. Manalili et al.). Applying the definition of accessories in Article 19, the Court observed that the elements require concealment to prevent discovery; here, discovery preceded the taking. The Court then turned to P.D. No. 1829, Section 1(b), which

Case Syllabus (G.R. No. 181111)

Parties and Procedural Posture

Jackson Padiernos y Quejada, Jackie Roxas y German, and Rolando Mesina y Javate filed a petition for review on certiorari seeking reversal of the Court of Appeals' decision dated May 10, 2007 and resolution dated December 20, 2007 in CA-G.R. CR No. 28920.
The People of the Philippines prosecuted the petitioners as accessories to a violation of P.D. No. 705 in Criminal Case No. 3122 before the Regional Trial Court, Branch 66, Baler, Aurora.
The Information alleged that the petitioners took away a ten-wheeler truck bearing Plate No. TFZ-747 to prevent its use as evidence and to avoid its confiscation and forfeiture as an instrument of the crime.
Accused Santiago Castillo, Frederico Castillo, and Roger Mostera remained at large, accused Eddie Gatdula pleaded not guilty as principal, and petitioners pleaded not guilty as accessories.

Key Factual Allegations

On November 15, 2002, a truck marked "JEROME" with Plate No. TFZ-747 was found in Caragsacan, Dingalan, Aurora loaded with 818 pieces of lumber totaling 10,253 board feet valued at P133,289.00 and lacking supporting transport documents.
DENR personnel led by DENRO Felimon Balico and police officers guarded the truck and transferred the lumber to police custody but left the truck guarded on the national highway.
On November 16, 2002, Santiago and the petitioners arrived, Santiago handed the truck key to Mesina who started the truck, and the petitioners boarded with DENROs boarding the back of the truck.
The truck accelerated toward Nueva Ecija, leaving the police escorts who fired warning shots, and the Filipino Army later intercepted the truck at Brgy. Bagting, Gabaldon, Nueva Ecija where the occupants alighted and the truck was recovered.

Prosecution Evidence

DENRO Felimon Balico testified that he approached the truck and the driver and helper failed to produce supporting transport documents for the lumber.
The DENRO group and police officers guarded the truck overnight and removed the lumber to police custody between November 15 and 16, 2002 while leaving the truck guarded.
Witnesses testified that Santiago gave the truck key to Mesina, Mesina started the engine, the vehicle sped off while DENROs and policemen sought to stop it, and warning shots were fired by the policemen in pursuit.
Testimony established that the Army blocked the road and flagged down the truck, that petitioner Padiernos uttered words challenging the DENROs' right to apprehend the truck, and that police later retrieved the truck.

Defense Evidence

Mesina testified that Santiago asked him to bring the truck to Cabanatuan City and that he initially refused because the truck had been previously involved in illegal activities but relented after assurance from Santiago.
Roxas testified that he initially refused to drive the truck because he knew it was a "hot" truck but agreed after Santiago assured him there was no problem.
Padiernos testified that he was waiting for a ride and only joined Santiago's group en route to Cabanatuan City and that he only learned of the truck's exact location upon arrival at Caragsacan.
The petitioners denied hearing policemen's warning shots and DENROs' shouts on the ground that the truck's engine was noisy and side mirrors or windows were defective.

RTC Ruling

The Regional Trial Court convicted the pet