Title
Revaldo vs. People
Case
G.R. No. 170589
Decision Date
Apr 16, 2009
Petitioner convicted for illegal possession of premium hardwood lumber without permits; warrantless search upheld under plain view doctrine; penalty modified due to unproven lumber value.

Case Summary (G.R. No. 170589)

Charge and Information

Petitioner was charged with illegal possession of premium hardwood lumber under Section 68 of the Forestry Code. The Information alleged possession, on or about 17 June 1992 in Maasin, Southern Leyte, of 96.14 board feet of assorted premium hardwood lumber (specific pieces and species enumerated) valued at P1,730.52, without the legal documents required by forest laws and regulations. Petitioner pleaded not guilty.

Prosecution evidence and police actions

SPO4 Maceda testified that on 18 June 1992 at about 11:00 a.m. he and other PNP personnel went to petitioner’s house to verify a report by SPO3 Nicasio Sunit alleging possession of lumber without documents. They did not have a search warrant. They confiscated 20 pieces of lumber found around the house, which Maceda said were freshly cut. Maceda asked who owned the lumber; petitioner admitted ownership and said the lumber were for house repair and furniture-making. The lumber were loaded onto a patrol jeep and brought to the police station; the DENR was informed and took custody coordination. Forester Saguing later scaled the lumber and fixed the total volume at 96.14 board feet. Evidence custodian Lasala testified that only ten pieces remained in police custody because some pieces were damaged for lack of storage.

Defense evidence and testimony

Petitioner testified that he is a carpenter and was working on a commissioned divider when police arrived on 18 June 1992. He admitted he had no permit but claimed the lumber had been given to him by relatives (uncle Felixberto Bug-os, aunt Gliceria Bolo, mother-in-law Cecilia Tenio). He stated some pieces were leftovers from previous work and that the lumber were intended for house repair and for his furniture business. Candole testified that Bug-os hired him to cut a tree on Bug‑os’s land, have it sawed into lumber and deliver the lumber to petitioner; Candole added that policemen stopped them en route but permitted transport to petitioner’s house. Caalim corroborated petitioner’s testimony.

Trial court findings and conviction

The Regional Trial Court (Branch 25, Maasin) found petitioner guilty beyond reasonable doubt of violating Section 68 of the Forestry Code. The trial court emphasized petitioner’s failure to produce the persons (Bug‑os, Bolo, Tenio) who allegedly could have proven that prior DENR permission had been sought and obtained. The court treated the Forestry Code as a special law making criminal intent unnecessary for the offense of possession without legal documents. The trial court sentenced petitioner to an indeterminate term of four years and two months (prision correccional minimum) to eight years and one day (prision mayor maximum) and ordered confiscation and forfeiture of the lumber in favor of the government (CENRO Maasin), to be sold at public auction with proceeds to the National Treasury.

Court of Appeals ruling

The Court of Appeals affirmed the trial court on 23 August 2004, holding that motive or intention is immaterial and that mere possession of lumber without the required legal documents gives rise to criminal liability under Section 68.

Issues on review before the Supreme Court

Primary issues presented were: (1) whether the warrantless police intrusion and seizure at petitioner’s residence rendered the seized lumber inadmissible in evidence; (2) whether the police had authority to arrest and seize without warrant under the Forestry Code; (3) whether the prosecution sufficiently proved the value of the lumber for purposes of fixing the penalty.

Supreme Court’s analysis — search, seizure and plain-view doctrine

Petitioner argued the search and seizure were illegal because police lacked a search warrant and acted only on a verbal order based on prior information. The Court analyzed the seizure under the plain-view doctrine as articulated in People v. Doria and summarized in the decision: the plain-view doctrine applies when (a) the law-enforcement officer has a prior justification for being in the position to view the area; (b) the discovery of the evidence is inadvertent; and (c) it is immediately apparent to the officer that the item is evidence or contraband. The Court found that when police arrived the lumber were in plain view around petitioner’s house, petitioner admitted ownership but could not produce the required documents when asked, and thus there was probable cause to confiscate. The Court therefore concluded that the absence of a search warrant did not render the seizure invalid because the circumstances fit recognized exceptions to the warrant requirement under applicable jurisprudence and statutory authority.

Supreme Court’s analysis — statutory arrest/seizure authority under the Forestry Code

The Court relied on Section 80 of the Forestry Code (authorizing forest officers or DENR employees and PNP personnel to arrest without warrant any person who has committed or is committing in their presence any offenses defined in the forestry chapter and to seize tools, equipment and forest products used or taken in the commission of the offense). Applying Section 80, the Court held that police had statutory authority to arrest (if warranted) and to seize the lumber when petitioner was found in possession without legal documents. Because mere possession without documentation constitutes an offense under Section 68, Section 80 sanctions immediate seizure even without a warrant.

Nature of the offense and relevance of intent

The Court reiterated that Section 68 describes two distinct offenses: (1) cutting/gathering/collecting/removing timber without authority; and (2) possession of timber or forest products without the legal documents required by law. For the second category (possession without documents), the Forestry Code operates as a special law treating mere possession without required documents as malum prohibitum; therefore, the legality of the source of the lumber is immaterial and absence of intent is not a defense. Petitioner’s open-court admission of ownership and lack of documents was dispositive as to liability under the statute.

Penalty regime and evidentiary proof of value

Section 68 prescribes penalties under Articles 309 and 310 of the Revised Penal Code. The trial court initially applied Article 309(3) in relation to Article 310 based on the amount alleged in the Informat

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