G.R. No. 249027 , April 3, 2024
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, LEDDIE 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. [G.R. No. 249155] INMATES OF NEW BILIBID PRISON, AS REPRESENTED BY RUSSEL A. FUENSALIDA, TOSHING YIU, BENJAMIN D. GALVEZ, CERILO C. OBNIMAGA, URBANO D. MISON, ROLAND A. GAMBA, PABLO Z. PANAGA, AND ROMMEL T. DEANG, PETITIONERS, VS. SECRETARY MENARDO GUEVARRA, DEPARTMENT OF JUSTICE, SECRETARY EDUARDO AÑO, DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT, DIRECTOR GENERAL GERALD BANTAG, BUREAU OF CORRECTIONS, AND HON. ALLAN SULLANO IRAL, CHIEF, BUREAU OF JAIL MANAGEMENT AND PENOLOGY, RESPONDENTS.

FACTS

This case involves consolidated petitions concerning the grant of Good Conduct Time Allowance (GCTA). The ponencia has exhaustively discussed why specific sections of the 2019 Revised Implementing Rules and Regulations (IRR) of Republic Act No. 10592 should be nullified for being ultra vires. The dissenting opinion focuses on the statutory history and interpretation of Articles 29 and 97 of the Revised Penal Code, as amended by RA 10592, to determine who is entitled to or excluded from its benefits.

ISSUE

The core issue addressed in the dissenting opinion is the proper interpretation of the exclusionary provisions in Republic Act No. 10952 (which amended RA 10592), particularly concerning who is entitled to and who is excluded from credit for preventive imprisonment and good conduct time allowance, based on a comprehensive reading of its sections amending Articles 29 and 97 of the Revised Penal Code.

RULING

The dissenting opinion, penned by Justice Leonen, presents a detailed statutory analysis. It traces the legislative history of credit for preventive imprisonment from Act No. 2557 , through its codification in Act No. 3185 (the Revised Penal Code), and subsequent amendments by Republic Act No. 6127, Batas Pambansa Blg. 85, Executive Order No. 214, and finally Republic Act No. 10592 . The opinion highlights that early laws excluded specific offense-based categories (e.g., robbery, theft, estafa) from the benefit, a category later removed and then reintroduced in a different form. It notes that the amendment by RA 10592 inserted a proviso in Article 29 excluding “recidivists, habitual delinquents, escapees and persons charged with heinous crimes” from the coverage of the Act. The opinion contrasts this with the history of Article 97 (Allowance for Good Conduct), which had an earlier basis in Act No. 1533 and Act No. 2489. The dissent argues that to precisely determine entitlement and exclusion under RA 10952, all its sections—particularly Section 1 amending Article 29 and Section 2 amending Article 97—must be read together. The opinion implies that a holistic interpretation is necessary, rather than a piecemeal invalidation of IRR provisions, to fully comprehend the legislative intent regarding which persons deprived of liberty are disqualified from receiving GCTA and credit for preventive imprisonment.