People v. Padiernos
REITERATIONFacts
The Antecedents: The underlying dispute involves the alleged illegal possession of lumber, a violation of Presidential Decree No. 705, also known as the Forestry Reform Code of the Philippines. The prosecution's case centers on the discovery of a truck loaded with 818 pieces of lumber, valued at P133,289.00, without the requisite permits or documentation. The accused, including the principals and the petitioners as alleged accessories, were charged with this violation. The core of the charge against the petitioners was their subsequent act of taking away the truck that carried the lumber, allegedly to prevent its use as evidence and to avoid its confiscation and forfeiture by the government. Procedural History: The case originated with an Information filed before the Regional Trial Court (RTC), Branch 66, Baler, Aurora, charging several individuals, including the petitioners Jackson Padiernos, Jackie Roxas, and Rolando Mesina, as accessories to the crime of illegal possession of lumber. The RTC found the petitioners guilty as accessories and imposed a penalty. The petitioners appealed this decision to the Court of Appeals (CA). The CA affirmed the RTC's conviction but modified the penalty imposed. Aggrieved by the CA's ruling, the petitioners then filed the present petition for review on certiorari before the Supreme Court. The Petition: The petitioners seek the reversal of the Court of Appeals' decision and resolution, which affirmed their conviction as accessories to the crime of illegal possession of lumber. They argue that they cannot be held liable as accessories because the crime had already been discovered and the truck, along with the lumber, was already under the control of law enforcement authorities when they took the truck. They contend that their actions did not fall under the definition of accessories as provided by Article 19 of the Revised Penal Code, which requires the act to be for the purpose of preventing the discovery of the crime. The Supreme Court, in its review, considered whether the petitioners' actions constituted the crime of being accessories to the violation of P.D. 705 or if their conduct fell under a different offense, specifically obstruction of justice under P.D. 1829.
Issue(s)
Whether the petitioners are liable as accessories to the crime of illegal possession of lumber under P.D. 705. Whether the petitioners' acts constitute obstruction of justice under Section 1(b) of P.D. 1829.
Ruling
The Supreme Court GRANTED the petition, REVERSED the Court of Appeals' decision, and found the petitioners GUILTY of violation of Section 1(b) of P.D. 1829 (Obstruction of Justice). They were sentenced to suffer the penalty of prision correccional in its maximum period, which is 4 years, 9 months, and 11 days to 5 years, 4 months, and 20 days.
Ratio Decidendi
On the issue of liability as accessories to the crime of illegal possession of lumber under P.D. 705: The Court ruled that the petitioners are not liable as accessories under Article 19, paragraph 2 of the Revised Penal Code (RPC). This provision defines accessories as those who, with knowledge of the crime's commission, take part subsequent to its commission by concealing or destroying the body of the crime, its effects, or instruments, in order to prevent its discovery. In this case, the crime of illegal possession of lumber had already been discovered and the truck, along with the lumber, had been confiscated by the authorities on November 15, 2002. The petitioners took the truck on November 16, 2002, after its confiscation. Therefore, their act of taking the truck could not have been for the purpose of preventing the discovery of the crime, which had already occurred. The Court emphasized that the allegations in the Information determine the nature of the offense, and the factual allegations of taking and carrying away the truck to prevent its use as evidence and avoid confiscation were controlling, not the prosecutor's conclusion of law that they were accessories. On the issue of obstruction of justice under Section 1(b) of P.D. 1829: The Court found that the factual allegations in the Information, as proved during the trial, constitute the crime of obstruction of justice under Section 1(b) of P.D. No. 1829. This law penalizes acts that obstruct or frustrate the apprehension and prosecution of criminal offenders. Section 1(b) specifically covers altering, destroying, suppressing, or concealing any paper, record, document, or object with intent to impair its verity, authenticity, legibility, availability, or admissibility as evidence. The Court held that the truck, which carried the undocumented lumber, was material evidence indispensable in the criminal investigation and prosecution for violation of P.D. 705. By taking and carrying away the truck, the petitioners deliberately "suppressed" this evidence with the intent to impair its availability and prevent its use as evidence in the criminal investigation or proceeding. The petitioners' knowledge of the truck's involvement in illegal activities, their prior reluctance to drive it, Padiernos's aggressive reaction to the apprehension, and the RTC's ocular inspection findings all negated their defense of denial and established their common design to take the truck to suppress it as evidence.
Main Doctrine
The act of taking away a truck containing illegally possessed lumber, after the crime has already been discovered and the truck confiscated, does not constitute being an accessory to the crime of illegal possession of lumber under Article 19 of the Revised Penal Code, as the purpose of preventing discovery is absent. However, such act constitutes obstruction of justice under Section 1(b) of P.D. 1829, as it involves the suppression of an object with the intent to impair its availability and admissibility as evidence.