Facts:

The case involves Rafael Licera as the defendant-appellant and the People of the Philippines as the plaintiff-appellee. The events leading to this case began on December 3, 1965, when the Chief of Police of Abra de Ilog, Occidental Mindoro, filed a complaint against Licera for illegal possession of a Winchester rifle, Model 55, Caliber .30. The complaint was duly subscribed and sworn to by the Chief of Police. On August 13, 1966, the Municipal Court found Licera guilty and sentenced him to an indeterminate penalty of five years and one day to six years and eight months of imprisonment. Licera subsequently appealed this decision to the Court of First Instance of Occidental Mindoro. During the trial in the Court of First Instance, the parties agreed to jointly try the case of illegal possession of a firearm along with another case against Licera for assault upon an agent of a person in authority, both stemming from the same incident where Licera was apprehended by the Chief of ...

Facts:

Background of the Case

• On December 3, 1965, the Chief of Police of Abra de Ilog, Occidental Mindoro, filed a complaint against Rafael Licera for illegal possession of a Winchester rifle, Model 55, Caliber .30, without the requisite license or permit.
• Licera was apprehended on December 2, 1965, by the Chief of Police and a patrolman for possessing the firearm.

Legal Proceedings

• On August 13, 1966, the municipal court found Licera guilty of illegal possession of a firearm and sentenced him to an indeterminate penalty of five years and one day to six years and eight months of imprisonment.
• Licera appealed to the Court of First Instance of Occidental Mindoro, where the case was jointly tried with another charge against him for assault upon an agent of a person in authority, arising from the same incident.
• On August 14, 1968, the Court of First Instance acquitted Licera of the assault charge but convicted him of illegal possession of a firearm, sentencing him to five years of imprisonment and ordering the forfeiture of the rifle to the government.

Appeal to the Supreme Court

• Licera appealed to the Court of Appeals, which certified the case to the Supreme Court on October 16, 1974, as it involved a pure question of law.
• Licera argued that his appointment as a secret agent by Governor Feliciano Leviste of Batangas on December 11, 1961, exempted him from the requirement of a firearm license under the ruling in People vs. Macarandang.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Application of Judicial Decisions: Judicial decisions interpreting laws form part of the legal system and establish the legislative intent at the time of the law’s enactment. The Macarandang rule, which was in effect at the time of Licera’s appointment and apprehension, exempted secret agents appointed by provincial governors from the requirement of a firearm license.
2. Prospective Application of New Doctrines: When a new doctrine abrogates an old rule, the new doctrine should operate prospectively and not adversely affect those who relied on the old rule. This principle is particularly important in penal law, where the punishability of an act must be reasonably foreseen.
3. Reliance on the Macarandang Rule: Licera’s appointment as a secret agent in 1961 included a grant of authority to possess a firearm, and he relied on the Macarandang rule, which was valid at the time of his apprehension in 1965. The Mapa ruling, which revoked Macarandang, was issued in 1967 and should not apply retroactively to Licera’s case.

Conclusion:

• The Supreme Court acquitted Rafael Licera, holding that he incurred no criminal liability for possessing the Winchester rifle without a license, as he was exempt under the Macarandang rule in force at the time of his appointment and apprehension.