G.R. No. 173259 - Philippine National Bank vs. F.F. Cruz and Co., Inc.

On May 5, 2009, Task Force Davao of the Philippine Army flagged down Davao Metro Shuttle Bus No. 66 at a checkpoint near Tefasco Wharf, Ilang, Davao City. All male passengers were asked to disembark; female passengers remained on board.
SCAA Junbert M. Buco boarded the bus and examined passenger baggage. He discovered a small gray-black pack bag at the rear seat that felt unusually heavy.
The bus conductor identified petitioner Marcelo G. Saluday (wearing a white shirt) and his brother as seated at the back. Buco asked Saluday to open the bag. Inside were:

Petitioner could not produce a firearms or explosives license. He was arrested, Mirandized, and inquested before the City Prosecutor, which on May 7, 2009 found probable cause to charge him under PD 1866.

The Information (May 8, 2009) charged illegal possession of high-powered firearm, ammunition, and explosive without license. Petitioner pleaded not guilty.
Prosecution witnesses:

NUP Daniel Tabura (PNP-FED) who certified petitioner lacked any firearms registration.
SCAA Buco, who testified to the checkpoint inspection, identification of petitioner, opening of the bag, and seizure of the items.

Defense evidence: Petitioner testified he did not own the bag (his brother did), but admitted telling Buco its contents were “only a cellphone” and consenting—“yes, just open it”—to the bag’s opening.

RTC Branch 11, Davao City found petitioner guilty beyond reasonable doubt of illegal possession under PD 1866. Petitioner was sentenced on September 15, 2011 to prision mayor (minimum) and fined ₱30,000 for the firearm/ammunition count, and to prision mayor (maximum) plus ₱50,000 fine for the explosive count.
Petitioner appealed to the Court of Appeals.

In CA-G.R. CR No. 01099, petitioner argued misappreciation of evidence and illegality of the warrantless search; the OSG maintained the search was a valid consented inspection and factual findings stood.
The CA, in its Decision of June 26, 2014, dismissed the appeal but modified the sentence:

Illegal possession of firearm/ammunition: indeterminate term of 4 years, 8 months, 21 days (prision correccional maximum) to 7 years, 1 day (prision mayor minimum) plus ₱30,000 fine
Illegal possession of explosive: reclusion perpetua without eligibility for parole

On October 15, 2014, the CA denied petitioner’s Motion for Reconsideration as pro forma.

Petitioner filed a Petition for Review on Certiorari under Rule 45, raising only alleged errors in the legality of the search and the appreciation of evidence.
The Supreme Court treated the issues as pure questions of law and upheld the CA’s factual findings and legal conclusions.

Whether the warrantless inspection of the bus and petitioner’s bag at a military checkpoint violated Section 2, Article III of the Constitution.
Whether petitioner validly consented to the opening and search of his bag, thereby waiving his right against unreasonable searches.
Whether under Rule 45 the Supreme Court may disturb the factual findings of the RTC and the Court of Appeals.