Title
Inmates of the New Bilibid Prison vs. De Lima
Case
G.R. No. 212719
Decision Date
Jun 25, 2019
The case challenges the prospective application of R.A. No. 10592's IRR, arguing it violates Article 22 of the RPC, which mandates retroactive effect for beneficial penal laws. The Supreme Court ruled in favor of retroactive application, declaring the IRR invalid and ordering recomputation of time allowances for affected inmates.

Case Summary (G.R. No. 212719)

Key Dates

Enactment of R.A. No. 10592: June 6, 2013. IRR issued: March 26, 2014; effective April 18, 2014. Consolidation/filings: petitions filed in 2014 (Roxas et al., Edago et al.); intervenors filed July–October 2014. Decision: June 25, 2019 (applying the 1987 Constitution).

Applicable Law

Primary statutory source: R.A. No. 10592 (amending Articles 29, 94, 97, 98 and 99 of the Revised Penal Code). Governing constitutional framework: 1987 Constitution (notably due process and equal protection provisions, and protections against cruel, degrading or inhuman punishment). Controlling penal-law retroactivity principle: Article 22, Revised Penal Code (penal laws favorable to the accused are retroactive insofar as they benefit non-habitual criminals).

Central Issue Presented

Whether Section 4, Rule I of the IRR of R.A. No. 10592, which directs prospective application of the statute’s beneficial time-allowance provisions (GCTA, TASTM, STAL), is valid or whether it unlawfully denies retroactive application required by Article 22 of the Revised Penal Code and violates constitutional guarantees.

Statutory Background and IRR Provision Challenged

R.A. No. 10592 amended provisions on credit for preventive imprisonment, partial extinction of criminal liability, allowances for good conduct, special time allowance for loyalty, and who grants time allowances. The IRR’s Section 4, Rule I declared that the grant of GCTA, TASTM and STAL shall be prospective, citing the need for new procedures and the creation of Management, Screening and Evaluation Committees (MSECs).

Petitioners’ Contentions

Petitioners and intervenors argued the IRR’s prospectivity rule contradicts Article 22 of the RPC and is therefore invalid. They maintained the amendments are beneficial and therefore must be applied retroactively; that respondents exceeded authority and acted ultra vires in promulgating a rule that negates the statutory retroactivity; and that the rule discriminates in violation of equal protection and denies due process.

Respondents’ Defenses

Respondents asserted the prospectivity rule was justified because R.A. No. 10592 required new procedures, standards of behavior, and the creation of MSECs to uniformly implement the law; therefore, time allowances should be applied only prospectively. They also raised justiciability, standing, and hierarchy-of-courts objections.

Justiciability — Actual Case or Controversy and Ripeness

The Court found an actual case or controversy and that the issue was ripe. Although respondents argued the MSECs had not been constituted and no applications had been filed, the Court held that the dispute was ripe because the IRR’s issuance had a direct adverse effect: petitioners were currently detained and subject to potential longer incarceration because of the IRR’s prospectivity. The Court invoked precedent permitting adjudication without awaiting implementing acts where constitutional or statutory rights are directly affected.

Standing

The Court held petitioners had legal standing: they are detainees/convicts directly affected because the IRR’s prospectivity prevents consideration of their GCTA/TASTM/STAL entitlements, creating an immediate, concrete injury (extended incarceration). The absence of prior GCTAs was attributable to the IRR itself and thus did not defeat standing.

Appropriate Remedy and Jurisdictional Mode

Although the IRR is an administrative rule and the usual remedy would be an action for nullification in the RTC, the Court explained that petitions for certiorari and prohibition are proper in cases where constitutional issues and grave abuse of discretion by executive officials are involved. The Supreme Court accepted direct review in light of the national importance, the broad implications for the correctional system, and the urgent liberty interests at stake, justifying departure from strict hierarchy-of-courts technicalities.

Administrative Scope and Limits

The Court reiterated that administrative IRRs must be consistent with the statute and cannot expand or amend legislative provisions. The IRR went beyond the law by making retroactivity contingent on administrative steps (creation and operation of MSECs), which the amendatory statute did not condition upon. Administrative restructuring cannot be used to defeat substantive legal entitlements.

Substantive Analysis — Nature of R.A. No. 10592 and Application of Article 22

The Court analyzed whether R.A. No. 10592 constitutes a penal law favorable to the accused such that Article 22 mandates retroactive application. It concluded that, although the amendments do not define new crimes or prescribe new penalties, they reduce the punishment effectively by providing additional time credits and thus are beneficial. Consequently, Article 22 applies and the beneficial provisions should be retroactive insofar as they aid non-habitual criminals.

Rejection of Respondents’ Justification for Prospectivity

Respondents’ claim that “new procedures and standards” and the need to establish MSECs justified prospectivity was rejected. The Court found that core concepts (e.g., “good conduct”) and mechanisms for assessing conduct existed prior to the IRR (e.g., Classification Boards, historical practices, and the Bureau of Corrections operating manuals). The creation of MSECs did not appear as a statutory precondition for the law’s substantive benefits; thus, administrative convenience does not justify withholding those benefits retroactively.

Equal Protection and Due Process Considerations (Concurring Emphasis)

The concurring opinion (Justice Leonen) emphasized that prospectivity violated due process and equal protection by arbitrarily differentiating between inmates detained before and after the statute’s effectivity. That classification was not reasonably related to the statute’s rehabilitative aims, and it inflicted disproportionate and oppressive treatment on pre-effectivity detainees, amounting to cruel and unu

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