Facts:

The case involves Erwin Libo-on Dela Cruz (petitioner) against the People of the Philippines (respondent). The events leading to the case occurred on May 11, 2007, at the Cebu Domestic Port. Dela Cruz, an on-the-job trainee for an inter-island vessel, was at the pier to purchase a ticket to Iloilo. He left his bag on the floor with a porter while he bought the ticket, which took approximately 15 minutes. Upon returning, he placed his bag on an x-ray scanning machine for inspection. The x-ray machine operator, Cutie Pie Flores, detected what appeared to be firearms inside the bag and alerted baggage inspector Archie Igot. Dela Cruz confirmed ownership of the bag and consented to a manual inspection, which revealed three unlicensed revolvers and four live ammunition rounds. Dela Cruz was arrested and informed of his rights and the legal violations he committed. He was charged with illegal possession of firearms under Republic Act No. 8294 and violation of Commission on Election...

Facts:

1. Background: The case involves petitioner Erwin Libo-on Dela Cruz, who was charged with illegal possession of firearms during the 2007 election period.
2. Incident: On May 11, 2007, Dela Cruz was at the Cebu Domestic Port, intending to travel to Iloilo. He left his bag with a porter while purchasing a ticket. When he returned, he placed his bag on an x-ray machine for inspection.
3. Discovery: The x-ray machine operator, Cutie Pie Flores, detected what appeared to be three firearms inside Dela Cruz's bag. She alerted the baggage inspector, Archie Igot, who then called Port Police Officer Adolfo Abregana.
4. Search and Arrest: Upon manual inspection, three revolvers, NBI clearance, a seaman's book, and four live ammunitions were found in the bag. Dela Cruz admitted ownership of the bag but claimed he had no license for the firearms. He was subsequently arrested.
5. Charges: Dela Cruz was charged with illegal possession of firearms under Republic Act No. 8294 and violating the Gun Ban under Commission on Elections Resolution No. 7764 in relation to Section 261 of Batas Pambansa Blg. 881.
6. Trial Court Ruling: The Regional Trial Court found Dela Cruz guilty of violating the Gun Ban but dismissed the charge under Republic Act No. 8294. He was sentenced to one year of imprisonment, disqualification from holding public office, and deprivation of the right to suffrage.
7. Court of Appeals Decision: The Court of Appeals affirmed the trial court's decision, rejecting Dela Cruz's defense of denial and affirming the validity of the search.

Issue:

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Ruling:

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Ratio:

1. Possession of Firearms: The prosecution proved beyond reasonable doubt that Dela Cruz was in possession of unlicensed firearms during the election period without the necessary authorization from the Commission on Elections.
2. Waiver of Rights: Dela Cruz voluntarily submitted his bag for inspection, thereby waiving his right against unreasonable searches. His argument that the firearms were planted in his bag was deemed flimsy and unsupported by evidence.
3. Valid Search and Seizure: The search conducted by port authorities was reasonable and valid as part of routine security measures at the port. The x-ray scan, which revealed the firearms, provided probable cause for the manual inspection, and Dela Cruz consented to the search.
4. Burden of Evidence: Dela Cruz failed to prove his defense that the firearms were planted in his bag, and the burden of evidence shifted to him to disprove the prosecution's prima facie case.