G.R. No. 205015 , November 19, 2014
MA. MIMIE CRESCENCIO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Acting on information, DENR personnel went to petitioner Ma. Mimie Crescencio’s house on March 15, 1994, and saw forest products (lumber) lying under her house and at the shoreline nearby. When asked, the petitioner admitted ownership. The DENR personnel entered the premises without a search warrant and discovered 24 pieces of magsihagon lumber (452 board feet). The petitioner presented Official Receipt No. 35053 from Pengavitor Enterprises, but the species and dimensions of the lumber did not match the receipt. The DENR personnel confiscated the lumber and issued a seizure receipt. The petitioner was charged with violation of Section 68 of P.D. No. 705 (Revised Forestry Code), as amended, for illegal possession of forest products without the required legal documents. The Regional Trial Court (RTC) convicted the petitioner and sentenced her to imprisonment. The petitioner appealed to the Court of Appeals (CA), but the CA dismissed the appeal outright due to the petitioner’s failure to serve a copy of the Appellant’s Brief to the Office of the Solicitor General (OSG). The CA also denied the motion for reconsideration.

ISSUE

Whether the CA’s dismissal of the appeal due to the petitioner’s failure to serve a copy of the Appellant’s Brief to the OSG is proper, in view of the attendant factual circumstances and in the interest of substantial justice.

RULING

The Supreme Court ruled that the CA should have taken a liberal view of the rules. The rules of procedure should not be applied rigidly to override substantial justice, especially when the petitioner’s liberty is at stake. The Court found that the inadvertence of the petitioner’s counsel, which deprived her of due process and would result in the deprivation of her liberty, constituted a compelling reason to relax the technical rules. However, the Court further ruled that even setting aside the technicality, the prosecution proved the petitioner’s guilt beyond reasonable doubt. The warrantless seizure was valid under the plain view doctrine, as the lumber was plainly exposed to sight outside the house. Furthermore, forestry officers are authorized under the Forestry Code to arrest without a warrant and confiscate forest products when an offense is committed in their presence. The petitioner’s possession of the lumber, coupled with her failure to produce the required legal documents, constituted a violation of Section 68 of the Forestry Code. The petition was denied, and the RTC’s conviction was affirmed.