People vs.

Jabinal (Case Digest)

People vs. Jabinal

55 SCRA 607 27 February 1974

Antonio J.

Facts:

The instant case was an appeal form 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 vs. 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 vs. Macarandang and People vs. Lucero, the accused sought for his aquittal.

Noting and agreeing to the evidence presented by the accused, the trial court nonetheless decided
otherwise, citing that People vs. Macarandang and People vs. Lucero were reversed and subsequently
abandoned in people vs. 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:
The judgment appealed was reversed, and the appellant was acquitted.

Reason:

The doctrine laid down in lucero and Macarandang was part of the jurisprudence, hence, of the law, at
the time appellant was found in possession of fire arm in question and he was arraigned by the trial
court. It is true that the doctrine was overruled in Mapa case in 1967, but when a doctrine of the
Supreme Court is overruled and a new one is adopted, the new doctrine should be applied
prospectively, and should not apply to partres who had relied on the old doctrine and acted on the faith
thereof.