View full case

DEPARTMENT OF ENVIRONMENT v. GREGORIO DARAMAN

FACTS:

In this case, two accused individuals, Gregorio Daraman and Narciso Lucenecio, were charged with violating Section 68 of Presidential Decree No. 705 for unlawfully possessing and collecting lumber without the necessary permit. The prosecution presented a Forest Ranger named Pablo Opinion as a witness who testified that he stopped a vehicle and found lumber inside. The defense presented Daraman as their witness who testified that they were instructed to procure wood shavings and the lumber belonged to someone else. Based on the evidence presented, the accused were acquitted and the vehicle was ordered to be returned.

In a separate proceeding conducted by the Department of Environment and Natural Resources-Community and Environment and Natural Resources Office (DENR-CENRO), the seized lumber and vehicle were subjected to administrative confiscation. The DENR recommended the final confiscation of the seized items due to the failure of the accused to present documents proving the legality of their possession and transportation of the lumber. The RTC denied the motion for reconsideration filed by the DENR, ruling that the vehicle had already been administratively confiscated and forfeited. The trial court also found that the vehicle owner did not commit any violation and there was insufficient evidence to establish the possession of the lumber by Daraman. The DENR then filed a petition challenging the RTC's decision.

In another case, the PNP-ACTF impounded a vehicle after discovering illegally-sourced lumber in it. The PNP-ACTF filed a criminal complaint against the vehicle owner, but during the case's pendency, the RTC granted the owner's motion for the release of the impounded vehicle. The RTC cited the mistake, error, or failure of the officers handling the case as the basis for its decision. The PNP-ACTF opposed the release, arguing that the RTC lacked jurisdiction and that its interpretation of the law was incorrect. The PNP-ACTF also argued that the administrative confiscation should not be allowed due to its filing of the criminal action.

ISSUES:

  1. Whether the RTC had jurisdiction to order the return of the disputed vehicle.

  2. Whether the confiscation of the vehicle without due process is valid.

  3. Whether the validity and legality of the Order of Forfeiture falls under the review of the court.

  4. Whether the trial court misinterpreted PD 705 when it held that Section 68-A contemplates the owner of the vehicle being the violator or conspirator.

  5. Whether the failure of the assistant provincial prosecutor to comment on the Motion for Reconsideration constitutes an implied disapproval.

RULING:

  1. The RTC did not have jurisdiction to order the return of the disputed vehicle. The jurisdiction of the RTC covers the confiscation of timber or forest products as well as the machinery, equipment, implements, and tools illegally used in the area where the timber or forest products are found. On the other hand, the Department of Environment and Natural Resources (DENR) has jurisdiction over the confiscation of forest products and all conveyances used in the commission of the offense. Since the disputed vehicle is considered a conveyance used in the commission of the offense, the original and exclusive jurisdiction over its confiscation is vested in the DENR secretary or a duly authorized representative.

  2. The confiscation of the vehicle without due process is not valid. Private respondents argued that the Order of Forfeiture attached to the record was falsified and perjurious. It also appears that the vehicle was not in running condition. The Court did not further discuss this issue and did not make a ruling on it.

  3. The validity and legality of the Order of Forfeiture falls outside the review of the court. The trial court's jurisdiction is only limited to reviewing legal errors committed by a lower court. The actions and decisions of the DENR are reviewable by the courts only through special civil actions for certiorari or prohibition.

  4. The trial court erred in interpreting PD 705. Section 68-A contemplates a situation where the owner of the vehicle violated the law or conspired with others who violated it or consented to the use of his or her vehicle in violating it. The guilt or innocence of the accused in the criminal case is immaterial as what is penalized under Section 68 is the transportation of forest products without legal documents. The ruling on criminal liability is a function of the courts and not the DENR.

  5. The issue of whether the assistant provincial prosecutor's failure to comment on the Motion for Reconsideration constitutes an implied disapproval is no longer material. The public prosecutor's disapproval does not vest the trial court with the authority to release the vehicle to the private respondents.

PRINCIPLES:

  • Jurisdiction is conferred by substantive law.

  • If a statute is clear, plain, and free from ambiguity, it must be understood in its literal meaning and applied without resort to interpretation.

  • Machinery, equipment, and implements do not include conveyances, which are specifically covered by a different provision of the law.

  • The original and exclusive jurisdiction over the confiscation of conveyances used in violation of forestry laws is vested in the DENR secretary or a duly authorized representative.

  • Confiscation of property without due process is not valid.

  • The court's jurisdiction is limited to reviewing legal errors and the actions and decisions of the DENR are reviewable through special civil actions for certiorari or prohibition.

  • The interpretation of a statute is resorted to only where a literal interpretation would lead to absurdity or injustice.

  • The purpose and implementation of forestry laws should not be undermined by narrow constructions that frustrate its clear intent or unreasonably restrict its scope.