The Supreme Court has ruled that manufactured wood charcoal is not a forest product under Presidential Decree No. 705, as amended, and affirmed the dismissal of a criminal case filed against Rudy Villagen y Suelos. The Court denied the Petition for Review on Certiorari filed by the government and upheld the quashing of the Amended Information against him.
In its final disposition, the Court held that possessing or transporting manufactured wood charcoal does not constitute a punishable offense under Section 77 of P.D. No. 705, as amended, because charcoal is not included in the statutory definition of forest products.
The Case
Villagen was charged under P.D. No. 705, as amended, also known as the "Revised Forestry Code of the Philippines." According to the Information, on or about October 8, 2020, at around 7:00 in the morning in Barangay Labasan, Municipality of Bongabong, Province of Oriental Mindoro, Villagen, without any license, authority or legal documents, gathered, collected, and transported 475 sacks of manufactured wood charcoal with an estimated value of PHP71,250.00, loaded onto a red Hino wing van truck.
On November 23, 2020, Villagen entered a plea of "Not Guilty." On December 14, 2021, he filed a Motion to Quash the Information, arguing that the charge did not constitute an offense because manufactured wood charcoal is not considered a "forest product" under Section 3(q) of P.D. No. 705.
In an Order dated May 16, 2022, the Regional Trial Court (RTC) granted the Motion to Quash and dismissed Criminal Case No. CR20-11418. The RTC ruled that charcoal is a processed product and is not included in the enumeration of forest products under P.D. No. 705. It further held that the inclusion of charcoal in the definition under DENR Department Administrative Order (DAO) No. 97-32 could not amend or expand the scope of the penal statute.
The People of the Philippines, through the DENR as special prosecutor, filed a Motion for Reconsideration, which the RTC denied in an Order dated September 20, 2022. The prosecution then, through the OSG, filed a Petition for Certiorari and Prohibition before the Court of Appeals (CA), docketed as CA-G.R. SP No. 176218. In its Decision dated November 28, 2024, the CA granted the petition. The case eventually reached the Supreme Court.
The Issue
The question was whether manufactured wood charcoal falls within the definition of "forest products" under Section 3(q) in relation to Section 77 of P.D. No. 705, as amended, so that its possession or transportation without authority may be prosecuted as an offense.
The Ruling
The Court ruled that manufactured wood charcoal is not a forest product under Section 3(q) in relation to Section 77 of P.D. No. 705, as amended. It held that the facts alleged in the Amended Information, even if hypothetically admitted, do not constitute the offense charged.
The dispositive portion reads: "ACCORDINGLY, the Petition for Review on Certiorari is DENIED. The Resolution dated July 31, 2025, of Branch 42, Regional Trial Court, Pinamalayan, Mindoro Oriental in Criminal Case No. CR20-11418 is AFFIRMED. The Motion to Quash the Amended Information is GRANTED and Criminal Case No. CR20-11418 against respondent Rudy Villagen y Suelos is hereby DISMISSED. SO ORDERED."
By the Numbers
- Offense date: on or about October 8, 2020, around 7:00 in the morning
- 475 sacks of manufactured wood charcoal
- Estimated value: PHP71,250.00
- Plea of "Not Guilty": November 23, 2020
- Motion to Quash filed: December 14, 2021
- RTC Order granting the Motion to Quash: May 16, 2022
- RTC Order denying reconsideration: September 20, 2022
- CA Decision: November 28, 2024
- Criminal Case No. CR20-11418; CA-G.R. SP No. 176218; G.R. No. E-02082
The Court's Reasoning
The Court explained that administrative authority is limited to filling in the details for the proper enforcement of a law and does not extend to altering, enlarging, or supplanting the statutory text. This limitation applies with greater force to penal statutes. Criminal liability must rest on a clear and unequivocal provision of law and cannot be created or extended by implication, administrative interpretation, or regulation. Since P.D. No. 705, as amended, does not include charcoal within the definition of "forest products," such inclusion cannot be supplied by administrative fiat.
The Court found that the RTC committed no error in granting the Motion to Quash. Although the prosecution was given the opportunity to amend under Section 4, Rule 117 of the Rules of Court, the Amended Information continued to suffer from the same defect—charging an act that is not criminalized by Section 77 of P.D. No. 705, as amended.
The Court clarified that it is the act of possessing manufactured wood charcoal that is excluded from the coverage of Section 77. It noted that if the government believes the wood used to produce the charcoal was obtained through prohibited acts, the State may prosecute the person responsible. However, the Original and Amended Information did not allege that Villagen cut, collected, gathered, or removed a forest product without authority.
Invoking the maxim nullum crimen, nulla poena sine lege—there is no crime when there is no law punishing it—the Court stressed that criminal liability may be imposed only for acts clearly and unequivocally penalized by statute. It added that penal statutes must be construed strictly in favor of the accused, and any expansion of criminal liability to include manufactured wood charcoal as a forest product must come from Congress, not from judicial interpretation.
Source: Supreme Court decision in G.R. No. E-02082, People of the Philippines v. Rudy Villagen y Suelos.
This report summarizes a public Supreme Court decision and is not legal advice.