Case Summary (G.R. No. 104044)
Background of the Case
The conviction of Alexander Navaja originated from a buy-bust operation executed by the Anti-Narcotics and Dangerous Drugs Section (ANDDRUS) of the Cebu City Police Station on August 30, 1989. Despite not being apprehended immediately after the transaction, a complaint was filed against him on September 6, 1989, for violating Section 4, Article II of Republic Act No. 6425, popularly known as the Dangerous Drugs Act.
Information Filed
Following a preliminary investigation, an Information was prepared and filed on November 13, 1989, charging Navaja with selling approximately 100 grams of marijuana to a poseur-buyer, which he allegedly delivered without legal authority.
Arrest and Proceedings
After an initial period where he evaded arrest, Navaja was eventually apprehended on May 10, 1990, while attending to a habeas corpus case concerning illegal possession of firearms. The case was revived, and he was arraigned on July 2, 1990, where he pleaded not guilty.
Evidence Presented
During the trial, the prosecution presented testimonies from several key witnesses, including Pfc. Ranulfo Espina and chemists from the National Bureau of Investigation (NBI) and the Philippine Crime Laboratory, who confirmed that the substances presented were indeed marijuana. The defense presented Navaja’s testimonies and that of his mother and a friend, all asserting that he was not the person involved in the drug sale.
Court’s Findings
The trial court found the testimony of Pfc. Espina credible, noting that he made a positive identification of Navaja as the seller of marijuana. The court acknowledged the absence of corroborative witnesses but concluded that Espina's solitary testimony satisfied the burden of proof for conviction. The defense’s assertions that evidence was insufficient or that he was misidentified were deemed unconvincing.
Errors Assigned on Appeal
Navaja raised several errors in his appeal: questioning the reliability of Espina’s testimony, criticizing the trial court for not considering the absence of corroborating witnesses, alleging improper motives behind the prosecution, and claims of misidentification. Each of these assertions was addressed sequentially by the appellate court.
Evaluation of Credibility
The appellate court underscored the trial court's exclusive authority to assess the credibility of
...continue readingCase Syllabus (G.R. No. 104044)
Case Overview
- The case involves Alexander Navaja, who was found guilty of selling prohibited drugs, specifically marijuana, in violation of Section 4, Article II of Republic Act No. 6425, as amended.
- The Regional Trial Court (RTC) of Cebu sentenced Navaja to life imprisonment and imposed a fine of P20,000.00.
- The judgment was promulgated on October 14, 1991, leading to Navaja's appeal to the higher courts.
Facts of the Case
- The accused was implicated in a buy-bust operation conducted by the Anti-Narcotics and Dangerous Drugs Section (ANDDRUS) of the Cebu City Police on August 30, 1989.
- Following the operation, Navaja successfully evaded arrest after selling marijuana to poseur-buyers.
- A complaint was filed against him on September 6, 1989, and after a preliminary investigation, an Information was formally charged on November 13, 1989.
- The case was archived due to the accused's absence and was revived upon his arrest on May 10, 1990.
Evidence Presented
- The prosecution's witnesses included Pfc. Ranulfo Espina, who testified about the buy-bust operation, and forensic chemists who confirmed the marijuana's identity.
- The prosecution presented evidence showing that Navaja sold approximately 100 grams of marijuana, which was positively identified through field and laboratory tests.
- The defense presented witnesses who claimed that Navaja was not involved in dr