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1PERSONS AND FAMILY RELATIONS CASE DIGEST PART 2PEOPLE VS LICERAFACTS:In 1961, accused was granted an appointment as secret agentof Governor Leviste. In 1965, accused was charged with illegal possession offirearms. The SC held that where at the time of hisappointment, People v. Macarandang (1959) was applicable,which held that secret agents were exempt from the licenserequirement, and later People v. Mapa (1967) was decided,theearliercaseshouldbeheldapplicable.ISSUE: Which rule should be applied to the case at bar: thatenunciatedin Macarandang orthatin Mapa?HELD: Article 8 of the Civil Code of the Philippines decreesthat judicial decisions applying or interpreting the laws or theConstitution form part of this jurisdiction's legal system. Thesedecisions, although in themselves not laws, constituteevidence of what the laws mean. The application orinterpretation placed by the Court upon a law is part of the lawas of the date of the enactment of the said law since theCourt's application or interpretation merely establishes thecontemporaneous legislative intent that the construed lawpurports to carry into effect. At the time of Licera's designation as secret agent in 1961 andat the time of his apprehension for possession of theWinchester rifle without the requisite license or permit thereforin 1965, the Macarandang rule — the Courts interpretation ofsection 879 of the Revised Administrative Code - formed partof our jurisprudence and, hence, of this jurisdiction's legalsystem. Mapa revoked the Macarandang precedent only in1967. Certainly, where a new doctrine abrogates an old rule,the new doctrine should operate respectively only and shouldnot adversely affect those favored by the old rule, especiallythose who relied thereon and acted on the faith thereof. Thisholds more especially true in the application or interpretation ofstatutes in the field of penal law, for, in this area, more than inany other, it is imperative that the punishability of an act bereasonably foreseen for the guidance of society. Pursuant to the Macarandang rule obtaining not only at thetime of Licera's appointment as secret agent, whichappointment included a grant of authority to possess theWinchester rifle, but as well at the time as of his apprehension,Licera incurred no criminal liability for possession of the saidrifle, notwithstanding his non-compliance with the legalrequirements relating to firearm licenses.DE ROY VS CAFACTS:The firewall of a burned-out building owned by petitioner DeRoy collapsed and destroyed the tailoring shop occupied bythe family of private respondents, resulting to injuries to privaterespondents and the death of private respondent’s daughter. Petitioner had warned the private respondents to vacate theirshop in view of its proximity to the weakened wall but the latterfailed to do so.