The Supreme Court ruled that the Department of Environment and Natural Resources (DENR) has the authority to confiscate vehicles used in illegal logging activities, even if the vehicle owner is acquitted in a related criminal case. This decision clarifies the separate jurisdictions of the Regional Trial Court (RTC) and the DENR in addressing forestry law violations. The DENR’s administrative power to confiscate conveyances used in illegal logging aims to protect the country’s forest resources by deterring the use of vehicles in such unlawful activities. This ruling underscores the importance of complying with forestry laws and regulations, as vehicles used in their violation are subject to confiscation regardless of the owner’s criminal liability.

When an Acquittal Doesn’t Save Your Ride: DENR’s Confiscation Power

The case revolves around Gregorio Daraman and Narciso Lucenecio, who were charged with violating Section 68 of Presidential Decree No. 705, as amended, for possessing illegally gathered lumber. While they were acquitted by the Regional Trial Court (RTC) of Calbayog City due to insufficient evidence, the RTC also ordered the return of the vehicle used to transport the lumber to Lucenecio, the vehicle owner. However, the Department of Environment and Natural Resources (DENR) argued that it had already administratively confiscated the vehicle under Section 68-A of the same decree, which grants the DENR the authority to confiscate conveyances used in forestry law violations. The central legal question is whether the RTC had the jurisdiction to order the return of the vehicle, considering the DENR’s prior administrative confiscation.

Building on this, the Supreme Court clarified the distinct jurisdictions of the RTC and the DENR in cases involving forestry law violations. Section 68 of PD 705 pertains to the cutting, gathering, and possession of timber without a license, and it grants the court the power to confiscate the timber and related equipment. In contrast, Section 68-A specifically addresses the administrative authority of the DENR to confiscate illegally obtained forest products and, critically, “all conveyances used either by land, water or air in the commission of the offense.” This distinction is crucial because it carves out a specific area of jurisdiction for the DENR, separate from the criminal proceedings handled by the courts.

To further emphasize the DENR’s authority, the Court cited its own administrative order (AO No. 54-93) which provides guidelines for the confiscation, forfeiture, and disposition of conveyances used in violation of forestry laws. This order reinforces the DENR’s power to act administratively against vehicles used in illegal logging, irrespective of the outcome of any related criminal case. “In all cases of violations of this Code or other forest laws rules and regulations, the Department Head or his duly authorized representative, may order the confiscation of any forest products illegally cut, gathered, removed, or possessed or abandoned, and all conveyances used either by land, water or air in the commission of the offense and to dispose of the same in accordance with pertinent laws, regulations or policies on the matter.”

Moreover, the Supreme Court addressed the argument that the DENR’s order of forfeiture was somehow invalid or improperly obtained. The Court stated that the validity and legality of the forfeiture order were outside the scope of the review of the RTC’s decision. The RTC’s decision to release the vehicle was based solely on the acquittal of the accused in the criminal case, while the DENR’s forfeiture order was based on a separate administrative proceeding under Section 68-A. Since the private respondents did not appeal the DENR’s forfeiture order, its validity was presumed. Thus, the acquittal in the criminal case did not automatically nullify the DENR’s administrative action.

Furthermore, the Court addressed the RTC’s interpretation of Section 68-A, which the RTC believed required the vehicle owner to be directly involved in the illegal activity for the confiscation to be valid. The Supreme Court rejected this interpretation, stating that the law punishes the transportation or conveyance of forest products without legal documents, regardless of the owner’s direct involvement. The DENR’s authority under Section 68-A is not contingent on proving the owner’s criminal culpability; it is sufficient that the vehicle was used in the commission of the offense. The Court emphasized that the DENR does not possess criminal jurisdiction and, therefore, cannot make rulings on criminal guilt or innocence.

The Court also highlighted the importance of protecting the country’s forest resources and the need for vigilant enforcement of forestry laws. Allowing the release of vehicles used in illegal logging would undermine the purpose of these laws and frustrate their clear intent. The preamble of Executive Order 277 underscores the urgency to conserve the remaining forest resources for present and future generations. Strong public policy considerations necessitate that forestry laws be interpreted and applied in a manner that effectively protects these vital resources.

In conclusion, the Supreme Court’s decision in this case reinforces the DENR’s authority to protect the country’s forest resources by confiscating vehicles used in illegal logging activities. This ruling clarifies the distinct jurisdictions of the RTC and the DENR and underscores the importance of complying with forestry laws and regulations.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES (DENR) VS. GREGORIO DARAMAN, G.R. No. 125797, February 15, 2002