- Petitioner
- Padiernos
- Respondent
- People
- Citation
- G.R. No. 181111
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Brion, J.
- Decided
- August 17, 2015
Summary
Three petitioners were charged as accessories to illegal possession of lumber under P.D. 705 for taking away a truck that had been used to transport undocumented lumber. The RTC and CA convicted them as accessories, but the Supreme Court reversed the decision. The Court ruled that since the forestry crime had already been discovered when petitioners took the truck, they could not be liable as accessories under Article 19 of the RPC, which requires acts to prevent discovery of the crime. However, the Court found them guilty of obstruction of justice under P.D. 1829 for suppressing evidence with intent to impair its availability in criminal proceedings. The case demonstrates the distinction between accessory liability and obstruction of justice, and shows how the same factual allegations can constitute different crimes depending on the timing and purpose of the acts committed.