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JACKSON PADIERNOS Y QUEJADA v. PEOPLE

FACTS:

The petitioners, Padiernos, Mesina, and Roxas, filed a petition seeking the reversal of the Court of Appeals' decision affirming their conviction as accessories to the crime of violation of P.D. 705. They were charged with taking away the truck used in the illegal transport of lumber to prevent its use as evidence and to avoid confiscation and forfeiture.

Evidence presented by the prosecution showed that the truck was approached by DENRO Balico, who reported the lack of supporting documents for the lumber, leading to the involvement of the police. On the following day, accused Santiago, along with the petitioners, arrived at the place where the truck was held. Santiago claimed ownership and agreed to bring the truck to the police station. However, when Mesina drove the truck, it unexpectedly sped off towards Nueva Ecija and was later stopped by the Philippine Army.

Mesina claimed that Santiago asked him to bring the truck to Cabanatuan City, but he refused due to his knowledge of its involvement in illegal activities.

The RTC found the petitioners guilty based on the testimonies of the prosecution witnesses, disregarding their defense that they did not intentionally take the truck and did not hear warnings due to engine noise and defective windows. The CA affirmed the RTC's decision, ruling that the truck was an essential link in proving the offense and the petitioners' intent was not necessary to establish their liability.

Respondent claims that the petitioners' actions were aimed at preventing the discovery of the crime, as without the truck, the accused could easily produce transportation documents that did not match the volume of the confiscated lumber.

ISSUES:

  1. Whether the court is precluded from determining the correct criminal liability of the appealing accused and from imposing the corresponding punishment.

  2. Whether the petitioners are liable as accessories to the crime charged.

  3. Whether the factual allegations in the Information constitute obstruction of justice under Section 1(b) of P.D. 1829.

  4. Whether the petitioners are guilty of obstruction of justice under Section 1(b) of P.D. 1829.

  5. Whether the penalty imposed on the petitioners is proper.

  6. Whether the Labor Arbiter committed grave abuse of discretion in dismissing the complaint for illegal dismissal

  7. Whether the Court of Appeals erred in affirming the decision of the Labor Arbiter

RULING:

  1. An appeal throws the whole case wide open for review. The court is not precluded from determining the correct criminal liability and imposing corresponding punishment, even if not raised during the appeal.

  2. The petitioners are not liable as accessories to the crime charged. The allegations in the Information control in defining the crime for which the petitioners should stand trial. The factual allegations in the Information did not coincide with the legal definition of "accessories" under Article 19 of the Revised Penal Code (RPC).

  3. The factual allegations in the Information constitute obstruction of justice under Section 1(b) of P.D. 1829. Even though the petitioners are not liable as accessories, their acts of taking and carrying away the truck to prevent its discovery and avoid confiscation constitute obstruction of justice under P.D. 1829.

  4. The petitioners are guilty of obstruction of justice under Section 1(b) of P.D. 1829. They deliberately took and carried away the truck used in the illegal possession/transportation of lumber with the intent to impair its availability as evidence in the criminal investigation or proceeding. The petitioners' intent to take the truck and their knowledge of its involvement in illegal activities were established through testimonies, admissions, and other evidence presented during trial.

  5. The penalty imposed on the petitioners is proper. Under Section 1 of P.D. 1829, the penalty for obstruction of justice is prision correccional in its maximum period, or a fine ranging from P1,000.00 to P6,000.00 pesos, or both. The Court sentenced the petitioners to suffer the penalty of prision correccional for 4 years, 9 months, and 11 days to 5 years, 4 months, and 20 days.

  6. No, the Labor Arbiter did not commit grave abuse of discretion in dismissing the complaint for illegal dismissal. The court found that there was no actual dismissal since the complainant voluntarily resigned from her position.

  7. No, the Court of Appeals did not err in affirming the decision of the Labor Arbiter. The court upheld the finding that there was no illegal dismissal.

PRINCIPLES:

  • An appeal empowers the appellate court to correct errors in the appealed judgment, even if not raised.

  • The allegations in the Information determine the nature of the offense, and not the technical name assigned by the public prosecutor.

  • The legal definition of "accessories" under Article 19 of the RPC does not coincide with the factual allegations in the Information.

  • The factual allegations in the Information may constitute a different offense, in this case, obstruction of justice under Section 1(b) of P.D. 1829.

  • The crime of obstruction of justice under Section 1(b) of P.D. 1829 requires the willful obstruction, impeding, frustrating, or delaying of the apprehension of suspects and the investigation and prosecution of criminal cases by altering, destroying, suppressing, or concealing any paper, record, document, or object with the intent to impair its verity, authenticity, legibility, availability, or admissibility as evidence.

  • In determining guilt for obstruction of justice, the court considers the factual allegations in the information, the elements of the offense, and the evidence presented during trial.

  • Knowledge of the involvement of the object in illegal activities and the deliberate intent to suppress the object are essential elements of obstruction of justice. This can be proven through testimonies, admissions, and other evidence presented during trial.

  • The penalty for obstruction of justice under P.D. 1829 is prision correccional in its maximum period or a fine ranging from P1,000.00 to P6,000.00 pesos, or both.

  • Grave abuse of discretion requires capricious and whimsical exercise of judgment which is equivalent to lack or excess of jurisdiction.

  • To constitute a valid resignation, it must be voluntary, clear, and unconditional.