G.R. No. 224804 . September 21, 2016.
EFREN R. LEYNES, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

An Information was filed against petitioner Efren R. Leynes and others for violating Section 94 of the Philippine Fisheries Code ( R.A. No. 8550 ) in Polillo, Quezon. The charge alleged that they willfully entered, occupied, and converted a half-hectare mangrove forest area into a fishpond by cutting trees, excavating, and constructing a dike and outlet without any government license or permit. During trial, Leynes denied the charge, arguing his actions constituted rehabilitation, not conversion. He claimed the area had been a fishpond since 1970 when owned by his grandfather, who possessed a tax declaration for it. Leynes further asserted good faith, presenting a Certificate of Non-Coverage from the DENR for his improvements.
The Regional Trial Court convicted Leynes, rejecting his defenses. It ruled that a tax declaration for land not classified as alienable and disposable is invalid and that the Certificate of Non-Coverage did not exempt him from environmental laws, as only a fishpond lease agreement could provide such exemption. The Court of Appeals affirmed the conviction, considering a Letter of Appeal from Leynes, where he admitted to cutting trees in the area, as a judicial admission conclusive against him.

ISSUE

Whether petitioner Efren R. Leynes is guilty beyond reasonable doubt of illegally converting a mangrove forest into a fishpond under Section 94 of R.A. No. 8550 .

RULING

Yes, the Supreme Court affirmed the conviction. The offense of conversion under Section 94 requires: (1) the site is a mangrove forest; (2) there was conversion of the area into a fishpond; and (3) the accused made the conversion. The first and third elements were undisputed. On the second element, the Court clarified that “conversion” means the act of changing the character or use of the mangrove area. Leynes’s acts of cutting mangrove trees and constructing dikes and an outlet fundamentally altered the area’s character from a natural mangrove forest into a managed fishpond. His intent to rehabilitate or improve is immaterial; the law prohibits the act of conversion itself regardless of purpose.
The Court dismissed Leynes’s defenses. The tax declaration in his grandfather’s name is not proof of ownership, especially for forest land, and its issuance may itself be a criminal act under forestry laws. The Certificate of Non-Coverage did not authorize the conversion but merely indicated the project was not covered by the Environmental Impact Statement system; it explicitly stated it did not exempt the grantee from other environmental laws and permitting requirements. His judicial admission in the Letter of Appeal regarding tree-cutting bolstered the finding of conversion. Consequently, the penalty of six years and one day to twelve years imprisonment and an P80,000 fine was upheld.