Narciso B. Guinto (Released and Rearrested Prisoner N216P-3611), Inmates of New Bilibid Prison including Rommel Baltar, Esmundo Mallillin, Aldrin Galicia, Henry Alicnas, Denmark Juderial, Juanito Miñon, Jr., Fromencio Enacmal, Benjamin Ibañez, Ricky Bautista, Leddic Karim, Alfredo Romano, Jr., Mario Sarmiento, Danilo Morales, and Alex Rivera, Petitioners, vs. Department of Justice, Bureau of Corrections, Bureau of Jail Management and Penology, and Philippine National Police, Respondents.
[Consolidated with G.R. No. 249155]
FACTS
Before the Court are two consolidated Petitions for Certiorari and Prohibition under Rule 65. The petitioners are inmates of the New Bilibid Prison convicted of heinous crimes. They assail the validity of the 2019 Revised Implementing Rules and Regulations (2019 IRR) of Republic Act No. 10592 (the New GCTA Law) for excluding persons convicted of heinous crimes from the application of the Good Conduct Time Allowance (GCTA). The petitioners argue that the Court’s dispositive portion in the prior case of Inmates of the New Bilibid Prison v. De Lima (De Lima), which ordered the recomputation of time allowances for “petitioners and all those who are similarly situated,” did not distinguish between those convicted of heinous crimes and others. They contend that the respondents (the Department of Justice, Bureau of Corrections, Bureau of Jail Management and Penology, and Philippine National Police) committed grave abuse of discretion in enforcing this exclusion.
ISSUE
Whether the 2019 Revised Implementing Rules and Regulations of Republic Act No. 10592, which exclude persons convicted of heinous crimes from the benefits of the Good Conduct Time Allowance, are valid.
RULING
The Court DISMISSED the Petitions. The 2019 IRR’s exclusion of persons convicted of heinous crimes from GCTA benefits is VALID. The Court held that the exclusion is consistent with the legislative intent of Republic Act No. 10592. The law’s text, specifically Section 1 which amends Article 29 of the Revised Penal Code, explicitly provides that “recidivists, habitual delinquents, escapees and persons charged with heinous crimes are excluded from the coverage of this Act.” While this phrase refers to “persons charged,” the Court, examining the statute as a whole and its legislative history, concluded that the clear legislative intent was to also exclude those convicted of heinous crimes from earning GCTA. This interpretation aligns with the statute’s purpose of encouraging good behavior while recognizing the gravity of heinous crimes. The Court found that the 2019 IRR did not contravene the law but merely implemented this discernible legislative policy. Consequently, the respondents did not commit grave abuse of discretion in promulgating and enforcing the 2019 IRR.
