PEOPLE V.

LICERA [65 S 270 (1975)]

Facts: In 1961, accused was granted an appointment as secret agent of Governor
Leviste. In 1965, accused was charged with illegal possession of firearms. The SC
held that where at the time of his appointment, People v. Macarandang (1959) was
applicable, which held that secret agents were exempt from the license
requirement, and later People v. Mapa (1967) was decided, the earlier case should
be held applicable.
HELD: Art. 8 of the Civil Code decrees that judicial decisions applying or interpreting
the laws or the Constitution form part of this jurisdiction's legal system. These
decisions, although in themselves not law, constitute evidence of what the laws
mean. The application or interpretation placed by the courts upon a law is part of
the law as of the date of the enactment of the said law since the Court's application
or interpretation merely establishes the contemporaneous legislative intent that the
construed law purports to carry into effect.
A new doctrine abrogating an old rule operates prospectively and should not
adversely affect those favored by the old rule.