Department of Environment and Natural Resources v. Daraman
REITERATIONFacts
The Antecedents: Gregorio Daraman and Narciso Lucenecio were charged with violation of Section 68 of Presidential Decree No. 705, as amended by Executive Order No. 277, for allegedly gathering, collecting, and possessing lumber without the necessary permits. A Forest Ranger intercepted a vehicle, the 'St. Jude' with Plate No. HAJ-848, driven by Daraman, and found lumber inside. Daraman claimed the lumber belonged to a certain Asan, who had merely asked him to transport it as a favor while he was collecting wood shavings. The vehicle and lumber were seized. Procedural History: The Regional Trial Court (RTC) of Calbayog City acquitted Daraman and Lucenecio for insufficiency of evidence and ordered the return of the vehicle to Lucenecio. The Department of Environment and Natural Resources (DENR) filed a Motion for Reconsideration, arguing that the vehicle had already been administratively confiscated and forfeited by the DENR on December 2, 1993, and January 26, 1994, respectively, and that the DENR had exclusive jurisdiction over the confiscation of conveyances under Section 68-A of PD 705. The RTC denied the motion. The Petition: The DENR, through its Regional Executive Director Israel C. Gaddi, filed a Petition for Review on Certiorari with the Supreme Court, assailing the RTC's Decision and Order, primarily on the grounds that the RTC had no jurisdiction to order the return of property already owned by the government, that the RTC disregarded provisions of PD 705, and that the government was not estopped from protecting its interests.
Issue(s)
Whether the Regional Trial Court (RTC) had jurisdiction to order the return of the confiscated vehicle. Whether the RTC misinterpreted Presidential Decree No. 705, as amended by Executive Order No. 277 (Revised Forestry Code). Whether the government is estopped from protecting its interest by reason of mistake, error, or failure of its officers to perform their duties.
Ruling
The Supreme Court granted the petition, reversed, and set aside the assailed Decision and Order of the RTC. The Court ruled that the RTC had no jurisdiction to order the return of the vehicle, as the DENR had exclusive authority to confiscate and forfeit conveyances used in violating forestry laws.
Ratio Decidendi
On the issue of jurisdiction to order the return of the vehicle: The Supreme Court held that the RTC overstepped its jurisdiction when it ordered the return of the vehicle. Section 68-A of PD 705, as amended by EO 277, explicitly grants the Department Head or their duly authorized representative the power to order the confiscation of all conveyances used in the commission of offenses involving forest products. This jurisdiction is distinct from the criminal jurisdiction of the courts, which pertains to the forest products themselves and the machinery or tools used. The Court emphasized that jurisdiction is conferred by substantive law, and PD 705 clearly delineates the DENR's authority over conveyances. On the interpretation of PD 705, as amended: The Supreme Court found that the RTC misinterpreted the law when it held that Section 68-A contemplated a situation where the owner of the vehicle was the violator or conspirator. The Court clarified that the guilt or innocence of the accused in the criminal case is immaterial to the administrative confiscation proceedings. Section 68-A covers the movement of forest products without proper documents, and the DENR's authority to impound vehicles is independent of any criminal ruling. The Court stressed that the plain and unambiguous language of the statute must be applied literally, and that a narrow construction would frustrate the clear intent of the law to conserve forest resources. On the issue of estoppel: The Court deemed it unnecessary to resolve the third issue regarding estoppel. Since the RTC lacked jurisdiction to release the vehicle, the alleged failure of the assistant provincial prosecutor to comment on the motion for reconsideration was rendered immaterial. The public prosecutor's disapproval, or lack thereof, does not vest in the trial court the jurisdiction or authority to release the vehicle when such authority is exclusively vested in the DENR.
Main Doctrine
The Department of Environment and Natural Resources (DENR) has exclusive jurisdiction over the confiscation and forfeiture of conveyances used in the commission of offenses under the Revised Forestry Code, separate from the criminal jurisdiction of the courts over the forest products themselves.