Case Summary (G.R. No. 212719)
Challenge to IRR Section 4, Rule I
The IRR directs that GCTA, TASTM, and STAL apply prospectively only, despite Art. 22’s mandate for retroactivity of penal laws favorable to non‐habitual offenders.
Procedural History of G.R. No. 212719
Petition filed June 18, 2014 by Roxas et al.; interventions by Atty. Saguisag and FLAG; consolidated comment by OSG.
Procedural History of G.R. No. 214637
Petition filed October 24, 2014 by Edago et al.; comments by BJMP and OSG; reply noted.
Justiciability and Standing
Court held an actual case or controversy and ripeness existed because IRR’s mere issuance adversely affected inmates’ liberty. Petitioners have direct personal stake and sustained injury in delayed release.
Hierarchy of Courts and Proper Remedy
Despite RTC as proper forum for declaratory relief under BP 129, En Banc Court accepted direct resort due to national importance, urgency of liberty rights, and absence of factual disputes.
Penal Law Retroactivity Principle
Article 22 RPC grants retroactive effect to penal laws favorable to accused. RA 10592’s benefits diminish punishment and thus must apply retroactively to non‐habitual offenders.
Nature of Good Conduct Time Allowance
GCTA and related credits have existed since early penal legislation; IRR’s “new standards” and MSEC creation mirror preexisting classification boards and manual procedures.
Validity of Prospective Application
Prospective rule arbitrarily disadvantages inmates convicted before RA 10592 by denying time credits, violating Art. 22 RPC, due process, equal protection, and amounting to cruel punishment.
Reconstitution of MSEC and Administrative Overreach
Respondents exceeded legislative mandate by condition
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Procedural History and Consolidation
- Two separate petitions filed under G.R. No. 212719 and G.R. No. 214637 challenged Section 4, Rule I of the IRR of R.A. No. 10592.
- Petitioners included convicted inmates of New Bilibid Prison and intervenors led by Atty. Rene A.V. Saguisag, Sr., William M. Montinola et al., and the Free Legal Assistance Group.
- Respondents comprised DOJ Secretary De Lima, DILG Secretary Roxas, BUCOR Acting Director Bucayu, and BJMP Chief Superintendent Mamaril.
- Draft comments and consolidated pleadings were filed by the Solicitor General and respondents; petitioners filed replies with leave of court.
- The Supreme Court, per Resolution of June 16, 2015, consolidated both cases for joint resolution.
Factual Background
- On May 29, 2013, R.A. No. 10592 amended Articles 29, 94, 97, 98, and 99 of the Revised Penal Code to enhance good conduct time allowances (GCTA), time allowances for study, teaching and mentoring (TASTM), and special time allowances for loyalty (STAL).
- The statute authorized DOJ and DILG Secretaries to promulgate IRR “as may be necessary to implement” its provisions.
- On March 26, 2014, the DOJ and DILG jointly issued the IRR of R.A. No. 10592, effective April 18, 2014.
- Section 4, Rule I mandated that all allowances under R.A. No. 10592 be applied prospectively and conditioned upon creation of a Management, Screening and Evaluation Committee (MSEC).
- Prior to the IRR, prison authorities already applied similar standards and had classification boards performing analogous functions.
Issues for Resolution
- Whether Section 4, Rule I of the IRR, providing for purely prospective application of GCTA, TASTM, and STAL, is lawful.
- Whether respondents exceeded their rule-making authority and violated the retroactivity principle of Article 22, RPC.
- Whether petitioners have justiciable interest, standing, and a proper remedy before this Court.
- Whether Section 4, Rule I also contravenes the Constitution’s equal protection, due process, and prohibition against cruel or inhuman punishment.
Petitioners’ Contentions
- R.A. No. 10592 is pe