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Case 2 - Inmates VS Et Al
Case 2 - Inmates VS Et Al
G.R. No. 212719 | June 25, 2019 | PERALTA, J. A petition was filed by inmates at the Maximum-Security Compound
of the New Bilibid Prison (NBP), challenging Section 4, Rule I of the
REYNALDO D. EDAGO, PETER R. TORIDA, JIMMY E. ACLAO, implementing rules and regulations (IRR) of Republic Act No. 10592
WILFREDO V. OMERES, PASCUA B. GALLADAN, VICTOR M. (RA 10592).
MACOY, JR., EDWIN C. TRABUNCON, WILFREDO A. PATERNO,
FEDERICO ELLIOT, and ROMEO R. MACOLBAS, Petitioners vs. The petitioners argue that the provision, which provides for the
SECRETARY LEILA M. DE LIMA, DEPARTMENT OF JUSTICE; prospective application of the law, is contrary to Article 22 of the
SECRETARY MANUEL A. ROXAS II, DEPARTMENT OF THE Revised Penal Code and violates public policy.
INTERIOR AND LOCAL GOVERNMENT; ACTING DIRECTOR
FRANKLIN JESUS B. BUCAYU, BUREAU OF CORRECTIONS; AND They also claim that the provision violates the Equal Protection
JAIL CHIEF SUPERINTENDENT DIONY DACANAY MAMARIL, Clause and substantive due process.
BUREAU OF JAIL MANAGEMENT AND PENOLOGY, Respondents
The Bureau of Jail Management and Penology (BJMP) and the
G.R. No. 214637 | June 25, 2019 | PERALTA, J.
Office of the Solicitor General (OSG) filed their respective
Facts of the Case: comments on the petition.
G.R. No. 212719 The petitioners were granted leave to file a reply, which was noted
by the court.
Several petitions and petitions-in-intervention were filed challenging
the retroactive application of Republic Act No. 10592 (RA 10592), Issue of the Case:
which amended the provisions of the Revised Penal Code regarding
the computation of good conduct time allowance for prisoners. Whether or not the provision states that the grant of good conduct time
allowance under the said law shall be prospective in application due to the
The petitioners argue that the implementing rules and regulations introduction of new procedures and standards. The main issue to be
(IRR) contradict the law and should have a retroactive effect to determined is whether this provision contradicts the Constitution and the
benefit the inmates. Revised Penal Code (RPC), rather than examining whether the acts
implemented are in violation.
They claim that the distinctions between the relevant provisions of
the law and the RPC are easily identifiable and that the records of
The Ruling of the Court:
The court has ruled in favor of the petitioners, declaring Section 4, Rule 1 of
the Implementing Rules and Regulations (IRR) of the Republic Act (R.A.)
No. 10592 as invalid. The provision, which mandates the prospective
application of the grant of good conduct time allowance, time allowance for
study, teaching, and mentoring, and special time allowance for loyalty, is
deemed contrary to Article 22 of the Revised Penal Code (RPC) and the
Constitution. The court affirms that R.A. No. 10592, although not explicitly a
penal law, diminishes the punishment attached to the crime and therefore
falls under the purview of Article 22. The prospective application of the law,
in this case, works against the interests of the petitioners and similarly
situated individuals, extending their sentence, and increasing their
punishment. The court orders the re-computation of time allowances and the
immediate release of the petitioners and others in the same situation unless
they are confined for other lawful reasons.
Dispositive Portion:
SO ORDERED.