Facts:

This case involves several consolidated petitions, notably G.R. No. 211559 and G.R. No. 211567, filed in 2014. The petitioners include Eric F. Acosta and Nathaniel G. Dela Paz, both licensed firearm owners, and the Peaceful Responsible Owners of Guns, Inc. (PROGUN). They challenged the constitutionality of certain provisions of the Comprehensive Firearms and Ammunition Regulation Act (Republic Act No. 10591), specifically the Implementing Rules and Regulations (IRR), which was formally enacted on May 29, 2013.

The provisions in question mandated the centralization of all firearms licensing applications and renewals at the Philippine National Police (PNP) headquarters in Camp Crame, Quezon City, along with the requirement for applicants to sign a Consent of Voluntary Presentation for Inspection. Acosta and Dela Paz claimed that these provisions violated their rights under Article III, Section 2 of the Constitution concerning unreasonable searches and seizures.

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Facts:

Background of the Case

The case involves consolidated petitions challenging the constitutionality of certain provisions of Republic Act No. 10591, also known as the Comprehensive Firearms and Ammunition Regulation Act, and its 2013 Implementing Rules and Regulations (IRR). The petitioners argued that these provisions violated their rights to bear arms, property, and privacy.

Key Provisions Challenged

1. Centralization of Firearms Licensing: The Philippine National Police (PNP) centralized all firearms licensing applications and renewals at its headquarters in Camp Crame, Quezon City, which petitioners argued was inconvenient for those living far from Metro Manila.
2. Consent for Voluntary Inspection: The PNP required applicants to sign a "Consent of Voluntary Presentation for Inspection" in the firearm registration form, allowing the PNP to inspect their firearms at their residences. Petitioners claimed this violated their right against unreasonable searches and seizures under Article III, Section 2 of the 1987 Constitution.
3. Outsourcing of License Delivery: The PNP outsourced the delivery of firearm license cards to a courier service, which petitioners argued delayed the issuance of licenses and deprived them of the right to use their firearms during the waiting period.

Petitioners' Arguments

• Eric F. Acosta and Nathaniel G. Dela Paz: Filed a Petition for Prohibition, challenging specific provisions of RA 10591 and its IRR, particularly the "Consent of Voluntary Presentation for Inspection."
• PROGUN (Peaceful Responsible Owners of Guns, Inc.): Filed a Petition for Certiorari, Prohibition, and Mandamus, questioning the centralization of licensing, the inspection waiver, and the outsourcing of license delivery.
• Guns and Ammo Dealers Association of the Philippines: Filed a Petition for Mandamus and Certiorari, arguing that the centralization of licensing harmed their business and violated applicants' right to due process.

Temporary Restraining Order (TRO)

The Supreme Court issued a TRO on April 8, 2014, restraining the PNP from:

1. Centralizing firearms applications and renewals at Camp Crame.
2. Using courier services for delivering firearm license cards.
3. Implementing the "waiver and consent" requirement for firearm licensing.

The PNP was ordered to continue accepting applications at regional offices and reopen satellite offices and accredited testing centers.

Subsequent Developments

• PROGUN's Contempt Petition: PROGUN alleged that the PNP violated the TRO by continuing to require the inspection waiver and failing to fully reopen regional offices.
• Additional Petition by PROGUN: PROGUN filed another petition, arguing that RA 10591's requirement for existing firearm holders to reapply for new licenses under the new law was an ex post facto law. They also challenged the PNP's overregulation of firearm-related activities and imposition of unauthorized fees.

Issue:

1. Whether the "Consent of Voluntary Presentation for Inspection" in the firearm registration form violates the constitutional right against unreasonable searches and seizures.
2. Whether the centralization of firearms licensing at Camp Crame violates the rights of applicants, particularly those from far-flung areas.
3. Whether the outsourcing of license delivery to a courier service deprives licensees of their right to use firearms during the waiting period.
4. Whether RA 10591's requirement for existing firearm holders to reapply for new licenses constitutes an ex post facto law.
5. Whether the PNP exceeded its rule-making authority by imposing additional fees and regulations not authorized under RA 10591.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court upheld the constitutionality of RA 10591 as a whole but struck down specific provisions of its IRR, particularly those related to the inspection waiver, centralization of licensing, and unauthorized fees. The Court reaffirmed the importance of safeguarding constitutional rights, particularly the right to privacy and the inviolability of the home, while recognizing the State's authority to regulate firearms for public safety.