Title
People vs. Constantino
Case
G.R. No. 251636
Decision Date
Feb 14, 2022
Accused-appellants convicted for unauthorized occupancy and construction in foreshore area without permits, violating Water Code; appeal dismissed due to procedural error.
A

Case Summary (G.R. No. 251636)

Petitioner and Respondent (in the appeal)

Petitioner: the accused-appellants (who filed a notice of appeal). Respondent: the People of the Philippines (plaintiff-appellee), represented by the prosecutor who subscribed to the Information.

Key Dates

Relevant adjudications and filings (as presented): foreshore lease application filed June 10, 2005; alleged illegal occupation noted July 13, 2009; Building Official certification May 22, 2013; MTCC Decision convicting appellants March 7, 2016; RTC affirmed September 5, 2017; Court of Appeals affirmed November 21, 2018 and denied reconsideration June 17, 2019; appeal to the Supreme Court decided February 14, 2022.

Applicable Law and Constitutional Basis

Constitutional framework: 1987 Philippine Constitution (applicable because the decision date is post-1990). Statutory and regulatory sources relied upon: Presidential Decree No. 1067 (Water Code of the Philippines), particularly Article 91(B)(3) (unauthorized occupancy of river bank or seashore without permission), Article 51 (easement and shore margin limitations), and Article 93 (criminal actions under Article 91 to be brought before proper courts); Rules of Court provisions on appellate procedure (Rule 45 petition for review on certiorari; Rule 56 on mode and disposition of appeals), Rule 110 of the Rules of Criminal Procedure as discussed by the CA, and the Rules of Procedure for Environmental Cases (Rule 9) as cited. Also referenced in the decisions: Batas Pambansa Bilang 129 (judicial reorganization), and Executive Orders concerning agency mandates (EO Nos. 192 and 123).

Charge and Stipulation of Facts

Accused-appellants were charged in an Information alleging conspiracy and mutual assistance to occupy, build and construct structures in the foreshore area of Barangay San Pedro, Panabo City on or about July 13, 2009, without securing the necessary permit, thereby violating Article 91(B)(3) of PD 1067. At pre-trial the parties stipulated that: none of the complainants are officially employed with the National Water Resources Board; the accused reside outside the coastal area where structures stand; they are WSBFC members represented by Lasco; WSBFC filed a Foreshore Lease Application (FLA) received by CENRO on June 10, 2005 signed by Lasco; and CENRO issued a certification stating there was no approval of the FLA.

Prosecution Version and Evidence

The prosecution established that the accused-appellants, as WSBFC members, entered and occupied the foreshore area beginning January 2009 and constructed sheds, cottages and other structures and operated sari-sari stores without DENR approval of any foreshore lease and without required city business or building permits. Witnesses observed the occupation and structures on July 13, 2009. Notices to vacate issued by Panabo City and public notices by CENRO-DENR advising that a pending FLA does not authorize occupation were ignored. A May 22, 2013 certification by the Building Official stated none of the accused were issued building permits.

Defense Version and Claims

The defense admitted membership in WSBFC and physical occupation prior to July 13, 2009, and that WSBFC filed an FLA in 2005 for a beach resort over 93,497 sqm. They relied on municipal and barangay resolutions recognizing the area as a beach resort, contended ignorance of the need for permits for makeshift stores and business activity, and asserted that pending FLA status lawfully permitted occupation and economic activity. They also relied on MTCC injunctive relief and a December 4, 2009 MTCC decision in a forcible entry case (SCC No. 30-08) that restored their possession, contending that restoration and prior possession justified continued occupation. Finally, they asserted an alleged failure to exhaust administrative remedies.

MTCC Ruling (Trial Court)

The MTCC (Panabo City) convicted the accused-appellants under Article 91(B)(3) of PD 1067 and sentenced each to a fine of PHP 3,000 (with subsidiary imprisonment in case of insolvency). It held that a pending foreshore lease application does not authorize occupation, building or construction; the MTCC decision in SCC No. 30-08 restoring possession in a forcible entry action could not be used as a defense in a criminal prosecution under PD 1067; and the restoration was based on prior de facto possession disturbed by third parties, not on authority to build without permits.

RTC Ruling (First-level Appellate Court)

The Regional Trial Court affirmed the MTCC in toto. Key holdings: none of the accused or WSBFC obtained the permits required by law; construction without the required permit is a violative act per se; PD 1067 is a special law and the offense is malum prohibitum (criminal intent is immaterial); a pending foreshore lease application does not authorize occupation or construction; the area described as “foreshore” falls within the broader statutory concept of “seashore” under PD 1067 and thus within Article 51’s regulated shore margins; the forcible entry decision restoring possession did not validate subsequent occupation or construction without permits; and exhaustion of administrative remedies is not applicable to the criminal prosecution because Article 93 of PD 1067 expressly provides for judicial prosecution of offenses under Article 91.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC. It reasoned that a complaint may be initiated before the prosecutor’s office by persons or public officers (citing Rule 110) and that although CENRO is not the NWRB, CENRO staff filed a joint affidavit-complaint with the prosecutor’s office and the prosecutor subscribed the Information. The CA reiterated that “seashore” encompasses “foreshore” and that unauthorized occupancy of the shore (including foreshore) without permission is penalized under Article 91(B)(3). The CA also held that DENR’s role and interest in foreshore management rendered the complaint properly filed and that exhaustion of administrative remedies did not bar criminal prosecution.

Issue on Appeal and Procedural Disposition by the Supreme Court

The principal procedural issue identified by the Supreme Court was the appellants’ mode of appealing: they filed a notice of appeal instead of the proper remedy—a verified petition for review on certiorari under Rule 45. The Court cited Rule 45 (Section 1 and 2) and Rule 56 (Sections 3 and 6) to explain that an appeal to the Supreme Court from the Court of Appeals should be by petition for review on certiorari and that an appeal by notice of appeal is generally dismissed. Because the accused-appellants received the CA decision and resolution and then filed only a notice of appeal, the Supreme Court concluded that they employed the wrong mode of appeal, which did not toll the reglementary period for filing a Rule 45 petition. Their failure to seek the proper remedy within the prescribed period rendered the judgment final and executable and warranted dismissal of the improper appeal.

Supreme Court Substantive Holding and Legal Reasoning

Substantively, the Supreme Court affirmed the conviction. The Court highlighted the following points as determinative: the accused-appellants admitted they occupied and constructed structures in an area classified as foreshore without necessa

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