Case Summary (G.R. No. 174882)
Procedural History and Applicable Law
The petition before the Supreme Court is a Petition for Review under Rule 45 of the Rules of Court seeking to reverse the December 22, 2002 decision of the Court of Appeals (CA), which affirmed the finding of guilt by the Regional Trial Court (RTC) of Manila Branch 46. The charges stem from the alleged trafficking and possession of smuggled cigarettes, violating Section 3601 of the Tariff and Customs Code. The case was tried and decided under the framework of the 1987 Philippine Constitution.
Summary of Charges
Petitioner and co-accused were charged with conspiring to defraud the government by unlawfully importing 305 cases of assorted blue seal cigarettes without proper declaration and without paying the requisite duties and taxes. The government alleged petitioner knowingly participated in the unlawful importation and possession of these contraband goods.
Facts as Presented by the Prosecution
Col. Panfilo Lacson, then Chief of the Police Intelligence Branch of the Metrocom Intelligence and Security Group (MISG), received intelligence on syndicates engaged in smuggling in the Port Area. On October 15, 1979, his team intercepted a cargo truck registered to Teresita Estacio, accompanied by a Toyota Corona car. The truck was found to be carrying 305 cases of untaxed blue seal cigarettes. Several individuals, including petitioner Arturo Rimorin, were detained in connection with the intercepted goods. The driver of the cargo truck escaped. The accompanying military and police personnel found in the Toyota were not carrying mission orders.
Petitioner’s Version of the Facts
Petitioner claimed that he accompanied a man named Leonardo ("Boya") who had sought his assistance in hauling goods. He asserted ignorance of the illegal nature of the cargo, believing they were transporting household fixtures or rice. According to petitioner, the route taken was unusual, and upon interception by Metrocom agents, he was unaware of the actual contraband inside the truck. He suggested they were framed, pointing out the suspicious escape of the driver "Boya" while the rest were apprehended.
Court of Appeals’ Ruling
The CA affirmed the RTC's finding that petitioner was guilty beyond reasonable doubt. It held that the defense of denial was outweighed by the testimonial and documentary evidence presented by the prosecution. Importantly, the CA ruled that the failure to produce the seized contraband in court was not fatal to the prosecution’s case. The appellate court found sufficient evidence of possession and control over the smuggled goods by petitioner, whereas other co-accused not in possession were acquitted due to lack of evidence.
Issues for Supreme Court Review
Petitioner raised the following issues:
- Whether the CA’s decision involved a question not yet settled by the Supreme Court.
- Whether the lower courts erred in:
a) Not dismissing the case for failure to produce the seized goods (corpus delicti);
b) Presuming petitioner’s knowledge of the contraband without evidence;
c) Admitting into evidence the notice of sale and auction results without court order or notifying petitioner;
d) Relying on photographs instead of the seized goods; and
e) Not acquitting petitioner for reasonable doubt.
Legal Analysis: Corpus Delicti and Presentation of Evidence
The Supreme Court explained that corpus delicti means the fact of the commission of the crime and does not necessarily require physical presentation of the contraband. It suffices that the prosecution establishes (1) a certain fact constituting the crime occurred, and (2) a particular person is criminally responsible. The Court emphasized that corpus delicti can be proved through credible testimony, even from a sole witness, or through circumstantial evidence. The testimony of Col. Lacson and the Custody Receipt issued by the Bureau of Customs for the confiscated cigarettes adequately established the seizure and existence of contraband. The Court underscored the presumption of regularity in the performance of official duties by public officers.
Legal Analysis: Petitioner’s Knowledge of the Illegal Nature of the Cargo
Under Section 3601 of the Tariff and Customs Code, possession of smuggled goods raises a presumption of knowledge of the illegal nature thereof unless satisfactorily explained by the accused. Once possession is established, the burden shifts to the accused to prove lack of knowledge. The Court found petitione
...continue readingCase Syllabus (G.R. No. 174882)
Nature and Procedural Posture of the Case
- The case is a Petition for Review under Rule 45 of the Rules of Court filed by Arturo G. Rimorin Sr., seeking to reverse the Court of Appeals’ (CA) December 22, 2002 Decision in CA-GR CR No. 17388.
- The CA modified the February 18, 1994 Judgment of the Regional Trial Court (RTC), Manila (Branch 46), affirming Rimorin’s conviction for smuggling under the Tariff and Customs Code.
- The CA affirmed the guilt of Rimorin and his co-accused Felicisimo Rieta, Pacifico Teruel, and Carmelo Manaois, while acquitting other accused for lack of evidence.
- The judgment mainly concerns the possession and illegal importation of 305 cases of untaxed "blue seal" cigarettes found inside an intercepted cargo truck.
Factual Background and Evidence Presented
- On October 12-15, 1979, Metrocom Intelligence and Security Group (MISG) surveillance, led by Col. Panfilo Lacson, monitored smuggling activities near the Port Area, Manila.
- At around 4:00 a.m. on October 15, 1979, a green cargo truck with plate No. T-SY-167 emerged from the 2nd COSAC Detachment accompanied by an escorting Toyota Corona car with four men identified as belonging to the COSAC Detachment.
- The truck was intercepted, revealing 305 cases of assorted brands of blue seal (untaxed) cigarettes.
- The truck driver escaped, while occupants – including petitioner Rimorin (Pasay City Police Force), Rieta (Kawit Police Force), and civilian Gonzalo Vargas – were apprehended.
- Petitioner’s defense narrated a different version where he claimed ignorance of the smuggled cargo, having accompanied a man named "Boya" on what he believed were innocent errands; he denied knowledge of the cigarettes.
- Petitioner and co-accused argued they were framed, questioned the handling of the seizure, and objected to sufficiency of evidence, especially the absence of physical presentation of seized cigarettes in court.
Issues Presented for Resolution
- Whether the failure to present the physical seized goods (blue seal cigarettes) in court constitutes failure to prove corpus delicti.
- Whether petitioner had knowledge that the cargo transported was illegal or contraband.
- Whether the sale of the seized goods without prior notice to petitioner was proper or violated his rights.
- Whether the CA erred in its acceptance of the prosecution's evidence and refusal to acquit petitioner despite alleged doubts.
Legal Doctrine on Corpus Delicti in Smuggling Cases
- Corpus delicti lega