Republic of the Philippines

Department of Environment and Natural Resources

COMMUNITY ENVIRONMENT AND NATURAL RESOURCES
OFFICE
Maasin City, Southern Leyte
Tel. Nos. (053)381-2125, (053)570
December 2, 2021

NPS DOCKET NO.___________________

The Hon. Prosecutor

Office of the Provincial Prosecution
Maasin City, Southern Leyte

LETTER-COMPLAINT

The undersigned OIC CENR Officer, EDILBERTO R. ALCARDE formally

accuses CHITO CARIGARA MARATAS and ADONIS BIONG, both residents of Brgy.
Ilihan, Macrohon, Southern Leyte, for violation of Section 68 of Presidential Decree No.
705, as amended, to wit:

Cutting, gathering and/or collecting timber or other products without license. Any

person who shall cut, gather, collect, or remove timber or other forest products
from any forest land, or timber from alienable and disposable public lands, or
from private lands, without any authority under a license agreement, lease,
license or permit, shall be guilty of qualified theft as defined and punished under
Articles 309 and 310 of the Revised Penal Code; Provided, That in the case of
partnership, association or corporation, the officers who ordered the cutting,
gathering or collecting shall be liable, and if such officers are aliens, they shall,
in addition to the penalty, be deported without further proceedings on the part of
the Commission on Immigration and Deportation.

Having committed as follows:

“That on December 1, 2021, at around 9 o’clock in the evening, the above respondents
were caught by the PNP Personnel of Macrohon, in the act of gathering or carrying sawn
Antipolo lumbers at Brgy. Ilihan, Macrohon, Southern Leyte, and within the jurisdiction of this
Honorable Office. That the above respondents therefore, did then and there, willfully, unlawfully
and feloniously gather forty-four (44) pieces of sawn ANTIPOLO lumbers, with a total estimated
volume of 268.99 board feet, having an estimated value of ₱18,829.30, without any
authority under a license agreement, lease, or permit from the proper government authority as
required under existing forest laws and regulations, to the damage and prejudice of the
government of the Philippines.

CONTRARY TO LAW.

Based on our records, no permit was issued by our office in favor of the
respondents. Thus, the act of gathering the sawn lumbers was without a doubt illegal.

1
 Foregoing considered, it is most respectfully prayed that a preliminary investigation be
conducted so that the appropriate criminal charges may be filed in court against the above-
named respondents as the evidence so warrant.

Respectfully Yours,

EDILBERTO R. ALCARDE
OIC, CENR Officer

Attached documents:

1. Certification from the CENRO

2. Joint Affidavit of Arrest
3. Affidavit of DENR Personnel
4. Apprehension Receipt
5. Seizure Receipt
6. Seizure Order
7. Photos