Title
People vs. Navaja
Case
G.R. No. 104044
Decision Date
Mar 30, 1993
Alexander Navaja is convicted of marijuana sale due to credible witness testimony and the rejection of his alibi, establishing guilt beyond reasonable doubt.
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Case Digest (G.R. No. 104044)

Facts:

  • Alexander Navaja was accused of selling marijuana, violating Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act).
  • The Regional Trial Court (RTC) of Cebu rendered its decision on October 14, 1991, in Criminal Case No. CBU-16994.
  • The buy-bust operation occurred on August 30, 1989, where Navaja allegedly sold around 100 grams of marijuana to undercover officers.
  • Although law enforcement witnessed the transaction, Navaja evaded arrest immediately after.
  • A complaint was filed on September 6, 1989, and an Information was prepared on November 13, 1989, after a preliminary investigation.
  • The case was archived due to Navaja's absence until his arrest on May 10, 1990, during a habeas corpus hearing for his mother.
  • He pleaded not guilty upon arraignment on July 2, 1990.
  • The prosecution presented witnesses, including Pfc. Ranulfo Espina, who testified about the operation and identification of Navaja.
  • The defense argued against the drug trade involvement and provided alibi witnesses.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the RTC's decision, finding Alexander Navaja guilty beyond reasonable doubt of selling prohibited drugs.
  • The court upheld the trial court's reliance on Pfc. Espina's testimony and di...(Unlock)

Ratio:

  • The Supreme Court noted that the trial court is best positioned to assess witness credibility based on demeanor and reliability.
  • There was no compelling reason to doubt Pfc. Espina's identification, as the transaction occurred in daylight and the distance of eight to ten meters ...continue reading

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