The Supreme Court held that multiple acts aimed at obstructing a single legal proceeding constitute only one count of obstruction of justice under Presidential Decree No. 1829, applying the principle of delito continuado. This ruling clarifies that even if several actions are taken, if they stem from a single criminal intent, they should be treated as one continuous offense, preventing multiple charges for the same underlying objective. This is particularly significant for ensuring that individuals are not subjected to double jeopardy for what is essentially a single, ongoing criminal endeavor. The case emphasizes that the prosecution must consider the unity of purpose behind related acts when determining the appropriate charges.
Single Intent, Single Crime: Delimiting Obstruction of Justice
The case of Noel Navaja v. Hon. Manuel A. De Castro revolves around Noel Navaja, who faced two separate charges of obstruction of justice. The first charge stemmed from an incident on March 9, 2004, where Navaja allegedly misrepresented to a witness, Ms. Marilyn Magsigay, that her attendance at a preliminary investigation hearing was unnecessary. The second charge, linked to the March 15, 2004 hearing, accused Navaja, along with Atty. Orwen Bonghanoy, of submitting a false affidavit purportedly executed by Ms. Magsigay. The central legal question was whether these two acts, committed days apart but within the same legal proceeding, constituted separate offenses or a single continuous crime under Presidential Decree No. (PD) 1829, which penalizes obstruction of justice. This determination has significant implications for Navaja, potentially exposing him to double jeopardy if prosecuted separately for both charges.
Following separate Informations filed, Navaja sought to quash the first charge, arguing that it should be absorbed by the second, as both arose from the same preliminary investigation, involved the same facts, and shared a single criminal intent: to obstruct the investigation. The Municipal Circuit Trial Court (MCTC) and the Regional Trial Court (RTC) both denied Navaja’s motion, holding that the violations were distinct offenses. The Court of Appeals (CA) affirmed these rulings, emphasizing the separate acts and locations of the alleged offenses. This prompted Navaja to elevate the matter to the Supreme Court, seeking a determination on whether the principle of delito continuado applied to his case, potentially limiting his liability to a single charge of obstruction of justice. Understanding the nuances of this principle is vital for legal professionals and anyone facing similar multi-act charges.
The Supreme Court reversed the CA’s decision, focusing on the principle of delito continuado, which applies when multiple acts arise from a single criminal intent. The Court referenced Section 1 of PD 1829, which outlines various acts constituting obstruction of justice:
Sec. 1. The penalty of prision correccional in its maximum period, or a fine ranging from 1,000 to 6,000 pesos, or both, shall be imposed upon any person who knowingly or willfully obstructs, impedes, frustrates or delays the apprehension of suspects and the investigation and prosecution of criminal cases by committing any of the following acts:
The Court emphasized that while Navaja’s actions occurred on different dates and locations, they were driven by a single criminal impulse: to obstruct the preliminary investigation in I.S. Case No. 04-1238. Referencing Santiago v. Garchitorena, the Court highlighted the elements of delito continuado:
According to Cuello Calon, for delito continuado to exist there should be a plurality of acts performed during a period of time; unity of penal provision violated; and unity of criminal intent or purpose, which means that two or more violations of the same penal provisions are united in one and the same intent or resolution leading to the perpetration of the same criminal purpose or aim.
Furthermore, the Court clarified that the concept of delito continuado is applicable to crimes penalized under special laws, supplementing such laws under Article 10 of the Revised Penal Code. This approach contrasts with the CA’s reliance on Regis v. People, where separate acts of malversation through falsification were deemed independent offenses. The Supreme Court distinguished Regis by pointing out that in that case, the accused’s actions on different dates did not stem from a single criminal impulse. This distinction is crucial in understanding when multiple acts should be treated as a single continuous crime.
In essence, the Court found that Navaja’s alleged acts were motivated by a singular intent to obstruct the preliminary investigation. Therefore, he should only face one charge under PD 1829. Since Navaja had already been charged and convicted in the MTCC-Tagbilaran, the case in MCTC-Jagna should be dismissed to prevent double jeopardy. This decision reinforces the principle that when multiple actions are part of a single criminal design, they should be treated as one continuous offense, ensuring fairness and preventing undue prosecution.
| What is delito continuado? | Delito continuado refers to a single crime committed through a series of acts arising from one criminal intent or resolution. It treats multiple actions as one continuous offense if they share a unified criminal purpose. |
| What was the main issue in this case? | The main issue was whether separate acts of obstruction of justice, committed days apart, constituted separate offenses or a single continuous crime under PD 1829. The court addressed whether the principle of delito continuado applied. |
| What is Presidential Decree No. 1829? | Presidential Decree No. 1829 penalizes obstruction of apprehension and prosecution of criminal offenders. It outlines various acts that constitute obstruction of justice, such as preventing witnesses from testifying or presenting false documents. |
| What did the Court rule about the charges against Navaja? | The Court ruled that Navaja’s actions, though separate, were driven by a single criminal intent to obstruct a preliminary investigation. Therefore, he should only be charged with one count of violation of PD 1829. |
| Why was the case in MCTC-Jagna dismissed? | The case in MCTC-Jagna was dismissed because Navaja had already been charged and convicted in MTCC-Tagbilaran for acts related to the same criminal intent. Pursuing both cases would constitute double jeopardy. |
| How did the Court differentiate this case from Regis v. People? | The Court distinguished this case from Regis v. People by noting that in Regis, the accused’s separate acts of malversation did not arise from a single criminal impulse. In contrast, Navaja’s actions were motivated by a unified intent to obstruct justice. |
| What are the elements of delito continuado as defined by Cuello Calon? | According to Cuello Calon, delito continuado requires a plurality of acts, unity of the penal provision violated, and unity of criminal intent or purpose. This means that multiple violations are united by a single intent leading to the same criminal aim. |
| Can the principle of delito continuado apply to special laws? | Yes, the concept of delito continuado can be applied to crimes penalized under special laws. Article 10 of the Revised Penal Code supplements special laws unless they provide otherwise. |
| What is the significance of this ruling? | This ruling clarifies that multiple acts stemming from a single criminal intent should be treated as one continuous offense. It prevents multiple charges for the same underlying objective, protecting against double jeopardy. |
The Supreme Court’s decision in Navaja v. De Castro provides crucial guidance on the application of delito continuado, particularly in the context of obstruction of justice. By emphasizing the unity of criminal intent, the Court ensures that individuals are not unfairly subjected to multiple prosecutions for actions that are essentially part of a single, ongoing criminal endeavor. This ruling safeguards against double jeopardy and promotes a fairer application of the law.
For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: NOEL NAVAJA VS. HON. MANUEL A. DE CASTRO, G.R. No. 180969, September 11, 2017
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