Case Digest (G.R. No. 249027)
Facts:
Narciso B. Guinto et al. v. Department of Justice, G.R. Nos. 249027 and 249155, April 03, 2024, Supreme Court En Banc, Singh, J., writing for the Court. Petitioners are inmates of the New Bilibid Prison — in G.R. No. 249027 Narciso B. Guinto (a released-and-rearrested prisoner N216P-3611) and other inmates convicted of heinous crimes (collectively, Guinto et al.), and in G.R. No. 249155 a separate group of inmates represented by Russel A. Fuensalida and others (collectively, Fuensalida et al.). Respondents are the Department of Justice (DOJ), Bureau of Corrections (BuCor), Bureau of Jail Management and Penology (BJMP), the Department of the Interior and Local Government (DILG) and the Philippine National Police (PNP), impleaded through the Office of the Solicitor General.The petitioners filed consolidated Petitions for Certiorari and Prohibition under Rule 65 challenging the September 16, 2019 Revised Implementing Rules and Regulations (the 2019 IRR) of Republic Act No. 10592 (the “New GCTA law”), alleging grave abuse of discretion insofar as the 2019 IRR excludes persons convicted of heinous crimes from entitlement to Good Conduct Time Allowance (GCTA). Guinto et al. sought class relief and a status quo ante order after some inmates — including Guinto, who had earlier been discharged and then ordered to surrender and rearrested — were affected by re-computations and surrender orders following this Court’s prior decision in Inmates of the New Bilibid Prison v. De Lima (854 Phil. 675, 2019).
The respondents, via the OSG and BJMP, opposed the petitions arguing, inter alia, that (a) certiorari/prohibition are not proper remedies to attack the 2019 IRR and that habeas corpus would be the proper remedy for alleged unlawful detention (citing Rule 102, Sec. 1), (b) the 2019 IRR was a valid exercise of delegated rule‑making to implement RA 10592, and (c) petitioners failed to exhaust administrative remedies. The Court required consolidated replies and, by resolution dated November 26, 2019, consolidated the two cases. The matter was li...(Subscriber-Only)
Issues:
- Are petitions for certiorari and prohibition proper remedies to challenge the 2019 IRR and the respondents’ implementation of RA 10592, or should petitioners have resorted to habeas corpus or other remedies?
- Whether the 2019 IRR (specifically Rule IV, Section 2; Rule VII, Section 2; and the last paragraph of Rule XIII, Section 1) validly disqualifies recidivists, habitual delinquents, escapees, and persons charged or convicted of heinous crimes from earning GCTA, or whether those provisions exceed the DO...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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