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 them¬selves 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.