Title
People vs. Macarandang
Case
G.R. No. L-12088
Decision Date
Dec 23, 1959
Moro Sumaguina Macarandang, appointed as a secret agent by the Governor, was acquitted of illegal firearm possession as the Supreme Court ruled his role classified him as a "peace officer," exempting him from licensing requirements.

Case Summary (G.R. No. L-12088)

Background of the Case

Moro Sumaguina Macarandang was charged with illegal possession of firearms, specifically a Riot Gun and ammunition. The charge stemmed from an incident that occurred on or about June 8, 1954, in the Municipality of Marantao, Lanao. The information filed against him alleged that he possessed these items without a proper license or permit from the competent authority, thereby violating laws governing firearm possession.

Admission of Ownership and Legal Argument

In the appeal, Macarandang admitted that he owned and possessed the firearm and ammunition stated in the information. However, he argued that his possession was legally justified through an appointment he received from the Governor of Lanao, Dimakuta, on October 1, 1953. This appointment designated him as a secret agent tasked with assisting in law enforcement and maintaining peace in the area. The text of the appointment letter indicated his authority to carry the specified firearm and was intended to facilitate his duties related to crime detection and public safety.

Evaluation of the Governor's Authority

The trial court concluded that the Governor lacked the authority to issue firearms licenses or permits. However, Macarandang’s defense hinged on the interpretation of section 879 of the Revised Administrative Code, which provides exemptions for "peace officers" regarding firearms licensing requirements. His appointment as a secret agent, aligned with his responsibilities in maintaining peace and order, placed him within the definition of a peace officer for the purposes of the law.

Interpretation of Legal Exemptions

The appellate court reviewed the nature of Macarandang's appointment and its alignment with the definition of a peace officer as provided in the Revised Administrative Code. It found that the responsibilities bestowed upon him, particularly the authority to execute public safety measures and detect crimes, justified his classification as a peace officer. Consequently, this interpretation supported his legal claim to possess the firearm wit

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