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Argoncillo vs. Court of Appeals, 292 SCRA 313

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Argoncillo vs.

Court of Appeals, 292 SCRA 313

Doctrine:

The doctrine of Sensory Object Evidence holds that objects presented in court, which are addressed to
the senses of the court, are admissible as evidence when they are relevant to the fact in issue. Section 1
of Rule 130 emphasizes that objects can be exhibited, examined, or viewed by the court if they are
pertinent to the case. This doctrine recognizes the importance of physical evidence in judicial
proceedings, allowing the court to directly perceive and evaluate tangible objects to determine their
relevance and probative value.

Facts:

Santiago Argoncillo, Richardo Balbona, and Policarpio Umiten were charged with illegal fishing using
explosives (dynamite).

The Regional Trial Court (RTC) of Roxas City found them guilty, and this decision was affirmed by the
Court of Appeals.

On May 7, 1990, a team conducted a surveillance operation in Ivisan Bay due to reports of rampant
illegal fishing.

The team heard an explosion and found the accused individuals diving into the water and throwing their
catch of fish to a nearby banca.

Three other individuals were standing on the rocky portions of an islet nearby.

The accused were apprehended, and the fish samples were examined by fish examiners who confirmed
that they were caught with the use of explosives.

The accused denied the charges and claimed they were engaged in legal fishing using a fishnet called
"patuloy."

Issue:

Whether the accused are guilty of illegal fishing with the use of explosives.

Ruling:

The accused are guilty of illegal fishing with the use of explosives.

The Supreme Court found that the lower courts correctly assessed the credibility of the prosecution
witnesses and the evidence presented.

The presumption of illegal fishing has been clearly established based on the fish samples examined and
the testimonies of the prosecution witnesses.

Use of Fish Samples as Evidence

The court addressed the issue of whether the fish caught by the petitioners were actually killed with
the use of explosives.
The prosecution presented fish samples that were examined by experts, who concluded that the fish
were caught with the use of explosives.

The court found that the examination of a random sample of the fish was sufficient to establish that
they were killed with explosives.

The Court rejected the arguments of the accused, including their claim of innocence based on the
absence of explosives in their possession and their alleged non-flight when the law enforcers arrived.

However, the trial court erred in imposing a straight penalty of twenty years imprisonment on the
accused.

The proper penalty for illegal fishing with the use of explosives is an indeterminate penalty ranging from
twenty to twenty-five years imprisonment.

The Court modified the decision of the Court of Appeals and sentenced the accused to an indeterminate
penalty of imprisonment ranging from twenty to twenty-five years.

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