Merida v.

People of the Philippines

G.R. No. 158182, June 12, 2008, 554 SCRA 366

Syllabus:
The Revised Rules of Criminal Procedure (Revised Rules) list the cases which must be initiated by a
complaint filed by specified individuals the non-compliance of which ousts the trial court of jurisdiction from trying
such cases. However, these cases concern only defamation and other crimes against chastity and not to cases
concerning Section 68 of PD No. 705, as amended. Further, Section 80 of PD No. 705 does not prohibit an interested
person from filing a complaint before any qualified officer for violation of Section 68 of PD No. 705, as amended.

Facts:
A certain Tansiongco discovered that Sesinando Merida cut a narra tree in his private land, the Mayod
Property. Tansiongco reported the matter to the punong barangay who summoned petitioner to a meeting. During
that meeting, Merida made extrajudicial admissions that he did cut the tree but claimed that he did so with the
permission of one Vicar Calix, who, he alleges, bought the Mayod Property from Tansiongco. Tansiongco again
reported the matter, this time with the DENR. Merida made the same extrajudicial admissions. Tansiongco filed a
complaint with the Provincial Prosecutor charging Merida with violation of Section 68 of PD No. 705. The Prosecutor
found probable cause and filed the information with the trial court. The trial court found Merida guilty as charged. The
Court of Appeals affirmed the trial court’s judgment.

Issues:
(1) Whether the trial court acquired jurisdiction over the case considering that it was filed by a private individual
and not by a DENR forest officer.

(2) Whether Merida is guilty of violating Section 68 of PD No. 705

Ruling:
(1) Yes. The trial court acquired jurisdiction.

According to the Revised Rules of Criminal Procedure, the list of cases which must be initiated by the
complainant does not include cases concerning Section 68 of PD No. 705. Moreover, “Section 80 of PD No. 705 does
not prohibit an interested person from filing a complaint before any qualified officer for violation of Section 68 of PD
No. 705, as amended.”

(2) Yes. Merida is guilty of violating Section 68 of PD No. 705.

Merida constantly represented to the authorities that he cut a narra tree in the Mayod Property. Therefore,
his extrajudicial admissions are binding on him.