When does statutory construction come in

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.