G.R. No.

L-30061 February 27, 1974

People vs. Jabinal

Facts:
The 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.
The accused admitted that on September 5, 1964, he was in possession of the revolver
and the ammunition described in the complaint, without the requisite license or 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 in 1959 and
People vs. Lucero in 1958, the accused sought for his acquittal.
The trial court decided otherwise, citing that People vs. Macarandang and People vs.
Lucero were reversed and subsequently abandoned in People vs. Mapa that was
decided on 1967.

Issue:
Whether Jabinal should be acquitted on the basis of Supreme Court rulings in
Macarandang and Lucero, or in view of the complete reversal in People v Mapa?

Held:
Decisions of the Supreme Court, under Article 8 of the New Civil Code states that
“Judicial decisions applying or interpreting the laws or the Constitution shall
form a part of the legal system”
The settled rule supported by numerous authorities is a restatement of legal maxim
“legis interpretatio legis vim obtinet” — the interpretation placed upon the written
law by a competent court has the force of law.
The doctrine of stare decisis enjoins adherence to judicial precedents. It requires
courts in a country to follow the rule established in a decision of the Supreme Court
thereof. That decision becomes a judicial precedent to be followed in subsequent cases
by all courts in the land. The doctrine of stare decisis is based on the principle that
once a question of law has been examined and decided, it should be deemed
settled and closed to further argument.
The doctrine laid down in Lucero and Macarandang was part of the jurisprudence,
hence, of the law, at the time Jabinal 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 parties who had relied on the old doctrine
and acted on the faith thereof.
The judgment appealed was reversed, and the Jabinal was acquitted.

xxx
FROM AGPALO:
While Supreme Court decisions form part of the law of the land, they are however
subject to Art 4 of the Civil Code which provides that “laws shall have no retroactive
effect unless the contrary is provided.”
This is expressed in the legal maxim, lex prospicit, non respicit, the law looks
forward, not backwards.
The rationale against retroactivity is based on the principle that retroactive application of
a law usually divests rights that have already become vested or impairs the obligations
of contracts and hence, unconstitutional.