G.R. No. 248255 - Civil Service Commission vs. Rodriguez

The case involves the People of the Philippines appealing against the conviction of Moro Sumaguina Macarandang.
Macarandang was charged and tried in the Court of First Instance of Lanao for the crime of illegal possession of firearms.
The information stated that on or about June 8, 1954, in the Municipality of Marantao, Province of Lanao, Macarandang unlawfully possessed a specific firearm and ammunition without the proper license or permit.

The accused was found in possession of one Riot Gun, a Winchester, 12 GA (Serial No. 942131).
Along with the firearm, he had in his custody and control eight rounds of ammunition.
The charge alleged that he did not possess the requisite license or permit issued by a competent authority, a requirement for the lawful possession of such arms.

In his appeal, Macarandang admitted to owning and possessing the firearm and ammunition.
He invoked his appointment as a secret agent issued by Governor Dimakuta on October 1, 1953, as his legal justification.
The appointment specifically authorized him to hold and carry one Riot Winchester Shotgun, 12 GA (Serial No. 942131), along with twenty rounds of ammunition.
The appointment further tasked him with assisting in peace and order campaigns and reporting on lawless and wanted elements within the Municipal District of Marantao.

While the trial court noted that the Governor did not have authority to issue a firearm license or permit, it was recognized that Section 879 of the Revised Administrative Code exempts “peace officers” from this licensing requirement.
The crux of the matter thus turned on whether his appointment as secret agent placed him within the ambit of a “peace officer” for the purposes of the exemption.

Whether the appointment of Moro Sumaguina Macarandang as a secret agent by Governor Dimakuta qualifies him as a “peace officer” under Section 879 of the Revised Administrative Code.
Whether the legal exemption granted to peace officers from possessing a license or permit for holding firearms applies to an individual appointed solely for secret service and peacekeeping purposes.
Whether the authority given by the appointment supersedes the administrative limitation that the Governor lacks power to issue a firearm license, thus justifying the accused’s possession of the firearm and ammunition.