G.R. No. 108031 - Development Bank of the Philippines vs. National Labor Relations Commission

On May 31, 2019, Antonio Abiang y Cabonce was charged under Republic Act No. 10591 for illegal possession of one .38-caliber revolver (no serial number), six live ammunitions, one live ammunition reload, without any license.
He pleaded not guilty at arraignment.

On May 22, 2019, RTC Judge Viterbo issued Search Warrant No. 033-17-FVV after being informed by the Firearms and Explosives Office (FEO) that petitioner was not a licensed firearm holder (Initial Verification Report, May 21, 2019; Certification, Aug. 20, 2019).
On May 31, 2019 at 4:20 a.m., a police team, with Barangay Captain Papilla and Kagawad Butay as witnesses, executed the warrant at petitioner’s house in Brgy. Cabaducan East, Nampicuan, Nueva Ecija. Police Corporal Pader found a black basin containing the revolver, live ammunitions, a reload, and fired cartridge cases. Items were marked (“MP,” “MP1”–“MP11”), inventoried, photographed, and deposited with the Nueva Ecija Police Crime Lab.

Petitioner claimed that police forced entry at 4:00 a.m., planted the firearm and ammunitions in his basin, and denied ownership.
Barangay witnesses testified they arrived after photos were taken; petitioner suggested a frame-up due to envy.

Convicted petitioner for illegal possession of firearm and ammunition, sentencing him to an indeterminate term of 2 years, 4 months, 1 day to 8 years, 6 months.
Found elements proven: discovery of a .38-caliber revolver with ammunition in petitioner’s house and lack of firearm license; defenses of denial and frame-up were rejected.

Affirmed conviction but modified the sentence to 8 years, 1 day (medium period) as minimum to 10 years, 8 months, 1 day as maximum.
Held: (a) RTC had jurisdiction; (b) Search Warrant was valid; (c) defenses lacked merit.

Petitioner filed a Rule 45 petition, contending: (a) lack of probable cause in the Information; (b) no waiver of right to question the warrant; (c) warrant invalid for want of probable cause and procedural defects.
Office of the Solicitor General (OSG) opposed, invoking presumption of regularity and procedural waiver for failure to file motion to quash/suppress.

Was the Search Warrant validly issued upon probable cause and with compliance to constitutional requirements?
Did the RTC have jurisdiction over the case despite petitioner’s claim of lack of probable cause in the Information?
Did petitioner waive his right to challenge the legality of the Search Warrant by not filing a motion to quash or suppress before the trial court?