G.R. No. 175289 ; August 31, 2011
CRISOSTOMO VILLARIN and ANIANO LATAYADA, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioners Crisostomo Villarin (Barangay Captain of Pagalungan, Cagayan de Oro City) and Aniano Latayada, along with co-accused Marlon Baillo and Cipriano Boyatac, were charged with violation of Section 68 of Presidential Decree No. 705 (The Forestry Reform Code), as amended. The Information alleged that on or about January 13, 1996, they willfully, unlawfully, and feloniously gathered and possessed 63 pieces of Apitong flitches with a total volume of 4,326 board feet, valued at ₱108,150.00, without any required authority or supporting documents. The prosecution evidence established that on December 31, 1995, Latayada, Boyatac, and others delivered and unloaded the timber near the Batinay bridge. The timber was later discovered hidden under coconut leaves. Investigation revealed the timber was requisitioned by Villarin for a bridge repair project. The DENR Strike Force Team seized the timber on January 13, 1996. The defense claimed Villarin commissioned the timber for a public bridge repair project due to public clamor, but admitted they did not secure the necessary permits from the City Engineer or DENR beforehand. The Regional Trial Court found Villarin, Latayada, and Boyatac guilty beyond reasonable doubt and sentenced them to an indeterminate penalty of 12 years of prision mayor as minimum to 17 years of reclusion temporal as maximum. It acquitted Baillo for lack of evidence. The Court of Appeals affirmed the RTC decision in all respects.

ISSUE

Whether petitioners are guilty beyond reasonable doubt of violating Section 68 of P.D. No. 705, as amended, for possession of timber without the required legal documents.

RULING

Yes, petitioners are guilty beyond reasonable doubt. The Supreme Court affirmed the decisions of the lower courts. The offense under Section 68 of P.D. No. 705 is malum prohibitum. Mere possession of timber without the legal documents required under forest laws and regulations makes one automatically liable. Lack of criminal intent is not a valid defense. The prosecution successfully proved all elements of the crime: (1) the accused possessed the timber; (2) the timber was of the Apitong species; (3) the possession was without the required legal documents. Petitioners’ claim that the timber was for a public bridge project is immaterial and does not constitute a valid defense. The law requires the necessary permits regardless of purpose. The Court found no merit in petitioners’ arguments regarding the credibility of witnesses and the alleged violation of their right to a preliminary investigation. The penalty imposed by the RTC, as affirmed by the CA, is within the range provided by law.