GR 212719; (June, 2019) (Digest)
G.R. No. 212719 & G.R. No. 214637, June 25, 2019
INMATES OF THE NEW BILIBID PRISON, ET AL. and REYNALDO D. EDAGO, ET AL., Petitioners, vs. SECRETARY LEILA M. DE LIMA, ET AL., Respondents.
FACTS
Petitioners are inmates who sought the retroactive application of Republic Act No. 10592 , a law which increased the good conduct time allowance (GCTA) credits for persons deprived of liberty. The law amended Articles 29, 94, 97, 98, and 99 of the Revised Penal Code. The Department of Justice and the Department of the Interior and Local Government issued the Implementing Rules and Regulations (IRR), specifically Section 4, Rule 1, which declared that the grant of GCTA under R.A. No. 10592 “shall be prospective in application.” The petitioners challenged this provision, arguing that the beneficial provisions of the law should apply retroactively to them, as they were already serving sentence at the time of the law’s enactment, in accordance with Article 22 of the Revised Penal Code.
ISSUE
The sole issue is whether Section 4, Rule 1 of the IRR of R.A. No. 10592 , which provides for the prospective application of the law’s grant of good conduct time allowance, is valid.
RULING
The Supreme Court declared Section 4, Rule 1 of the IRR invalid and unconstitutional. The Court ruled that R.A. No. 10592 , being a penal law that is favorable to the accused, must be given retroactive effect pursuant to Article 22 of the Revised Penal Code, which states that penal laws shall have retroactive effect insofar as they favor the person guilty of a felony. The Court emphasized that the retroactive application of favorable laws is a constitutional right of the accused. The IRR cannot contravene the law it seeks to implement. By mandating purely prospective application, the IRR Section effectively repealed Article 22 of the RPC, which the implementing agencies have no authority to do. The legislative intent for retroactivity is further supported by the law’s purpose of decongesting jails and rewarding rehabilitation. Therefore, the increased GCTA credits under R.A. No. 10592 must be applied to all qualified inmates, including those convicted prior to its effectivity, for the period of their imprisonment following the law’s passage. The prospective application clause in the IRR is an invalid addition not found in the statute itself.