G.R. No. 224469 , January 5, 2021
Diosdado Sama y Hinupas and Bandy Masanglay y Aceveda, Petitioners, vs. People of the Philippines, Respondent.

FACTS

Petitioners Diosdado Sama and Bandy Masanglay, members of the Iraya-Mangyan indigenous group, were charged with violating Section 77 of Presidential Decree No. 705 (the Revised Forestry Code) for cutting down a dita tree without a license or permit. The prosecution’s case relied on the testimony of Police Officer 3 Villamor Ranee, who stated that while on surveillance, his team heard a chainsaw and saw a tree fall in the mountainous area of Barangay Calangatan, Oriental Mindoro. Upon reaching the site, they found the petitioners holding a chainsaw next to the felled tree. PO3 Ranee admitted he did not personally witness the actual cutting of the tree. The petitioners invoked their rights as Indigenous Peoples, claiming the tree was within their ancestral domain, as evidenced by a Certificate of Ancestral Domain Claim (CADC) issued to the Iraya-Mangyan tribe.

ISSUE

Whether the evidence presented by the prosecution is sufficient to prove the guilt of the petitioners beyond reasonable doubt for violating Section 77 of the Revised Forestry Code.

RULING

No. The petition is granted, and the petitioners are acquitted based on reasonable doubt. The prosecution failed to meet the required quantum of proof beyond reasonable doubt. The testimony of the lone witness, PO3 Ranee, was insufficient as he admitted he did not see the petitioners cut the tree, only that they were holding a chainsaw afterward. Furthermore, the existence of the CADC covering the area where the tree was felled casts reasonable doubt on the ownership of the land and resources, which is integral to the prosecution’s case. The Court emphasized that in criminal cases, the burden of proof lies with the prosecution, and any reasonable doubt must be resolved in favor of the accused.