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1) The case involved the seizure of a truck by the DENR that was transporting forest products without the required documents. The driver failed to provide an explanation and the truck was confiscated and forfeited.
2) The owners of the truck filed a case in court seeking return of the truck before the appeal to the DENR secretary was resolved. The court ordered return of the truck.
3) The Supreme Court ruled that the courts should not have entertained the case because the owners did not exhaust their administrative remedies at the DENR. Pending appeal at the DENR meant administrative remedies were still available.
1) The case involved the seizure of a truck by the DENR that was transporting forest products without the required documents. The driver failed to provide an explanation and the truck was confiscated and forfeited.
2) The owners of the truck filed a case in court seeking return of the truck before the appeal to the DENR secretary was resolved. The court ordered return of the truck.
3) The Supreme Court ruled that the courts should not have entertained the case because the owners did not exhaust their administrative remedies at the DENR. Pending appeal at the DENR meant administrative remedies were still available.
1) The case involved the seizure of a truck by the DENR that was transporting forest products without the required documents. The driver failed to provide an explanation and the truck was confiscated and forfeited.
2) The owners of the truck filed a case in court seeking return of the truck before the appeal to the DENR secretary was resolved. The court ordered return of the truck.
3) The Supreme Court ruled that the courts should not have entertained the case because the owners did not exhaust their administrative remedies at the DENR. Pending appeal at the DENR meant administrative remedies were still available.
Presumption in favor of beneficial operation of statues
Paat v. CA G.R. No. 111107 January 10, 1997 Torres Jr., J.
FACTS On May 19, 1989, the truck of respondent Victoria de Guzman was seized by DENR because the driver could not produce the required documents for the forest products concealed in the truck. Jovito Layugan, the CENRO of Aritao, Cagayan, issued an order of confiscation of the truck and gave the respondent 15 days to submit an explanation, which the petitioner failed to do. On June 22, 1989, Regional Executive Director Rogelio Baggayan sustained the confiscation and ordered the forfeiture of the truck. Respondents filed a letter of consideration that was denied and the case was brought to the DENR Secretary. Pending resolution of the appeal, respondents filed a suit for replevin against petitioners Layugan and Baggayan in the RTC, which issued a writ ordering return of the truck. Petitioners filed a motion to dismiss with the trial court, contending that respondents failed to exhaust administrative remedies. The motion along with a subsequent motion for reconsideration, were both dismissed. A petition for certiorari was then filed with the Court of Appeals which sustained the trial courts order, ruling that the issue involved was a purely legal question. Case was brought to the SC.
ISSUE Whether the courts acted within their jurisdiction upon the matter
HELD No. The courts should not have entertained the case because of the doctrine of administrative remedies. The petitioners failed to exhaust the administrative remedies still available to them when they resorted to the courts. This can be seen by the fact that the appeal made to the DENR Secretary was still pending as of the date of filing with the court. The petitioners were not excused from adhering to the doctrine because the instant case does not fall within the exemptions contemplated therein. Firstly, the petitioners contend that they have been deprived of their right to due process making the case an exception. However, the SC held that due process does not necessarily require a hearing, and one may be heard also through pleadings. The rights of the parties were not violated as manifested by the opportunity given to them to present their side through the letter of reconsideration to the RED. Second, petitioners aver that the seizure and forfeiture was unlawful on the premise that the DENR did not have authority to do so, and that the truck was not used in the commission of a crime. A proper construction of the pertinent law however, shows that these assertions by the petitioners are without merit. Petitioners interpretation of Sec. 68 of PD 705, as amended, unduly restricts the intention of the law and undermines the other provision of Section 68-A. Under Sec. 68, it is the court that shall order the confiscation of illegal forest products, as well as tools and implements used. On the other hand, Sec. 68-A confers to the DENR authority to order confiscation of illegal forest products and all conveyances used, and to dispose of the same in accordance with law. Construction of the law, the words, phrases and sentences contained therein, should be in relation to the whole statute and also considering any amendments thereto. It should not be isolated to the specific provision in question. Also, construction must be done in a way that will give effect to the purpose it intended to achieve. EO 277 that added Sec. 68-A aims to supplant the inadequacies that characterize enforcement of forestry laws through criminal actions. Availment of administrative remedies entails lesser expenses and provides a speedier disposition of controversies, which in the present case is necessary because of the urgency to preserve the remaining forest resources of the country. If as provided in Sec. 68 that only the court can order confiscation, Sec. 68-A would serve no purpose at all and the benefits of administrative remedies cannot be enjoyed.
Additionally, the law is clear and explicit with regard to the crime committed by the petitioners. EO 277 amending Sec. 68 provides the act of cutting, gathering, collecting, removing, or possessing forest products without the required legal documents to be distinct criminal offenses from theft as defined in Art. 309 and 310 of the Revised Penal Code. However, the penalty to be imposed on such offense is still that which is provided for in the Revised Penal Code. Hence, the suit of replevin sustained by the court was an unjustified encroachment into the domain of the DENRs prerogative and the taking of the property in question was never unlawful to begin with.