G.R. No. 249027 & G.R. No. 249155, April 3, 2024
NARCISO B. GUINTO, ET AL. AND INMATES OF NEW BILIBID PRISON, AS REPRESENTED BY RUSSEL A. FUENSALIDA, ET AL., PETITIONERS, VS. DEPARTMENT OF JUSTICE, ET AL., AND SECRETARY MENARDO GUEVARRA, ET AL., RESPONDENTS.

FACTS

These are two consolidated Petitions for Certiorari and Prohibition. The petitioners are inmates of the New Bilibid Prison convicted of heinous crimes. They assail the validity of specific provisions in the 2019 Revised Implementing Rules and Regulations (2019 IRR) of Republic Act No. 10592 . The challenged provisions (Rule IV, Section 2 and Rule VII, Section 2 of the 2019 IRR) exclude recidivists, habitual delinquents, escapees, and persons deprived of liberty (PDLs) convicted of heinous crimes from earning Good Conduct Time Allowance (GCTA) and Special Time Allowance for Loyalty (STAL). The petitioners contend that RA 10592 itself does not contain such disqualifications for convicted prisoners, and thus, the 2019 IRR exceeded the law’s scope by adding these restrictions.

ISSUE

Whether Rule IV, Section 2, Rule VII, Section 2, and the last paragraph of Rule XIII, Section 1 (insofar as it disqualifies PDLs convicted after the effectivity of RA 10592) of the 2019 IRR of RA 10592 are valid, specifically regarding their exclusion of persons convicted of heinous crimes and other listed offenders from the benefits of GCTA.

RULING

The Concurring Opinion of Chief Justice Gesmundo agrees with the ponencia’s ruling to NULLIFY the challenged provisions. The opinion concurs that RA 10592, particularly Article 97 of the Revised Penal Code as amended, does not disqualify recidivists, habitual delinquents, escapees, or persons convicted of heinous crimes from earning GCTA benefits. The law uses the disjunctive “or” to separate two categories entitled to GCTA: (1) offenders qualified for credit for preventive imprisonment under Article 29, and (2) any convicted prisoner in any penal institution. The disqualifications in the 2019 IRR constitute an addition to the law not intended by the legislature, thereby exceeding the scope of the delegated legislative power. The matter of excluding such convicts is a policy question for Congress, not the courts. The Court must apply the clear and unambiguous letter of the law (verba legis).