GR 141211; (August, 2001) (Digest)
G.R. No. 141211 ; August 31, 2001
CITY WARDEN OF THE MANILA CITY JAIL, petitioner, vs. RAYMOND S. ESTRELLA, et al., respondents.
FACTS
During a jail visitation program on Law Day, September 18, 1999, the Integrated Bar of the Philippines National Committee on Legal Aid found thirty-four (34) prisoners in the Manila City Jail who they believed were entitled to be released after deducting time allowances for good conduct from their sentences. The prisoners, the respondents, requested their release from petitioner City Warden Rosendo M. Dial on this ground, invoking Articles 97 and 99 of the Revised Penal Code. The City Warden denied the request, stating that only the Director of the Bureau of Corrections could grant such allowances under Article 99. However, on October 11, 1999, the City Warden issued certifications of good behavior for each respondent, stating the date they should have been released if good conduct time allowances had been credited. As the respondents remained confined, they filed a petition for habeas corpus. The Regional Trial Court, Branch 52, Manila, granted the petition and ordered their release in an order dated November 22, 1999. The City Warden filed this petition for review.
ISSUE
Whether the Regional Trial Court correctly granted the writ of habeas corpus and ordered the release of the respondents based on their entitlement to good conduct time allowances under Article 97 of the Revised Penal Code.
RULING
No. The Supreme Court reversed the order of the Regional Trial Court. The Court held that while the respondents may be entitled to good conduct time allowances under Article 97, the grant of such allowances is, under Article 99, a function exclusively vested in the Director of the Bureau of Corrections for prisoners sentenced to more than three years of imprisonment, and in the city warden for those sentenced to three years or less. The City Warden’s certifications, which were based on the assumption that allowances were granted, did not constitute the actual grant of such allowances required by law. The writ of habeas corpus is not the proper remedy to compel the grant of good conduct time allowances; the appropriate remedy is to request the authorized official to grant the allowance, with mandamus being available if the official unlawfully neglects that duty. Furthermore, for detention prisoners (those not yet convicted) to be entitled to good conduct time allowances, they must comply with the condition under Act No. 1533 of voluntarily offering in writing to perform labor. The records did not show that the respondents had fulfilled this condition. Therefore, the respondents’ continued detention was not illegal, and the writ of habeas corpus should not have been issued. The Court ordered the respondents remanded to the custody of the City Warden.