People of the Philippines v. Jose Jabinal

The instant case was an appeal from the judgment of the Municipal Court of Batangas finding the accused guilty of the crime of illegal possession of firearm and ammunition. The validity of the conviction was based upon a retroactive application of the Supreme Court’s ruling in People v Mapa.

As to the facts, a determined by the trial court, the accused admitted that on September 5, 1964, he was in possession of the revolver and the ammunition described in the complaint was without the requisite license a permit. He however, contended that he was a SECRET AGENT appointed by the governor, and was likewise subsequently appended as Confidential Agent, which granted him the authority to possess fire arm in the performance of his official duties as peace officer. Relying on the Supreme Court’s decision in People v Macarandang and People v Lucero, the accused sought for his acquittal.

Noting and agreeing to the evidence presented by the accused, the trial court nonetheless decided otherwise, citing that People v Macarandang and People v Lucero were reversed and subsequently abandoned in people v mapa.

ISSUE:

Should appellant be acquitted on the bases of Supreme Court rulings in Macarandana and Lucero, or should his conviction stand in view of the completer reversal of Macarandang and Lucero doctrine in Mapa?

RULING:

Decisions of this Court, under Article 8 of the New Civil Code states that “Judicial decisions applying or interpreting the laws or the Constitution shall form a part of the legal system … .” The settled rule supported by numerous authorities is a restatement of legal maxim “legis interpretatio legis vim obtinet” — the interpretation placed upon the written law by a competent court has the force of law.

Article 8 of the New Civil Code states that “Judicial decisions applying or interpreting the laws or the Constitution shall form a part of the legal system.

The doctrine of stare decisis enjoins adherence to judicial precedents. It requires courts in a country to follow the rule established in a decision of the Supreme Court thereof. That decision becomes a judicial precedent to be followed in subsequent cases by all courts in the land. The doctrine of stare decisis is based on the principle that once a question of law has been examined and decided, it should be deemed settled and closed to further argument

Appellant was appointed as Secret Agent and Confidential Agent and authorized to possess a firearm pursuant to the prevailing doctrine enunciated in Macarandang and Lucero under which no criminal liability would attach to his possession of said firearm in spite of the absence of a license and permit therefor, appellant must be absolved. Certainly, appellant may not be punished for an act which at the time it was done was held not to be punishable.

The appellant was acquitted.

* Case digest by Lady Rubyge A. Denura, LLB-1, Andres Bonifacio Law School, SY 2017-2018