Primary Holding

The Supreme Court upheld that lumber is included within the term "timber" in P.D. No. 705, as amended, and its possession without appropriate legal documents is a punishable offense. It reversed the lower court’s ruling that dismissed the criminal case, reinstated the information, and directed the trial court to proceed with dispatch. The Court also affirmed the DENR's administrative authority to seize lumber and enforce forest laws.

Background

The case arose from DENR's seizure of lumber stockpiles from Mustang Lumber, Inc., claiming the company failed to present necessary documents proving the legal acquisition and transport of the forest products. The company contested the seizure as illegal and argued that "lumber" does not fall under the punishable scope of P.D. No. 705.

Facts

• 1. A surveillance operation by DENR led to the seizure of lumber stockpiles in Mustang Lumber’s premises.
• 2. The lumber seized included species such as almaciga, supa, and lauan, which required legal documentation under forestry laws.
• 3. Mustang Lumber failed to provide certificates of lumber origin and other transport documents during the seizure and after being granted time.
• 4. DENR imposed penalties, including suspension of permits, confiscation of lumber, and filing of criminal charges.

Arguments of the Petitioners

• 1. Mustang Lumber argued that possession of "lumber" was not criminalized under Section 68 of P.D. No. 705, as amended, and only "timber" or "forest products" were penalized.
• 2. The seizure was illegal since lumber is a processed product and not expressly covered by the law.

Arguments of the Respondents

• 1. DENR and the government contended that "lumber" is included in the term "timber" and is subject to forest laws and regulations.
• 2. The company’s failure to present legal documentation justified the administrative seizure and criminal prosecution.

Issues

• 1. Is "lumber" included in the definition of "timber" or "forest products" under P.D. No. 705 as amended?
• 2. Was the seizure of lumber and subsequent administrative and criminal proceedings lawful?

Ruling

• 1. Lumber as Timber: The Supreme Court ruled that "lumber," being a processed product of timber, is included under the term "timber" as used in P.D. No. 705. Thus, possession of lumber without legal documents is illegal.
• 2. Legality of Seizures: The DENR properly exercised its administrative authority when it seized lumber found without the required documents, pursuant to Section 80 of P.D. No. 705.

Doctrines

• 1. Ubi lex non distinguit nec nos distinguere debemus: Where the law makes no distinction, courts should not distinguish. The law's use of "timber" encompasses both raw and processed wood, including lumber.
• 2. Search of Moving Vehicles: Warrantless searches of moving vehicles carrying contraband or illegal materials are an exception to the rule requiring warrants.

Key Excerpts

• 1. "Lumber is included in the term timber as defined in forest laws... possession without documents constitutes a violation."
• 2. "The government must not tire in its vigilance to protect the environment."

Precedents Cited

• 1. People v. Lo Ho Wing, 193 SCRA 122 (1991): On warrantless searches of moving vehicles.
• 2. People v. Fernandez, 239 SCRA 174 (1994): On exceptions to the warrant requirement.

Statutory and Constitutional Provisions

• 1. Presidential Decree (P.D.) No. 705: Sections 68 and 80 on unauthorized possession of forest products and administrative confiscation.
• 2. 1987 Philippine Constitution: Article III, Section 2 (search and seizure).
• 3. DENR Administrative Orders: Relevant to lumber and forest product definitions.