Navaja v. De Castro

Summary

This Supreme Court case established important precedent on the application of delito continuado doctrine to special penal laws. Noel Navaja was charged with two separate violations of PD 1829 for obstructing justice - preventing a witness from testifying and presenting a false affidavit - both aimed at impeding his wife's preliminary investigation. While lower courts ruled these were separate offenses prosecutable independently, the Supreme Court applied delito continuado principles, holding that acts motivated by a single criminal impulse to achieve one objective constitute a single crime. The Court dismissed one case to prevent double jeopardy, emphasizing that legal principles from the Revised Penal Code apply supplementarily to special laws. This decision clarifies when multiple acts under special penal laws should be treated as one continuous crime rather than separate offenses.