The Supreme Court has declared that inmates should benefit from the Good Conduct Time Allowance (GCTA) law retroactively. This means that prisoners who were incarcerated before the enactment of Republic Act No. 10592 are also entitled to avail of the time allowances for good behavior, study, teaching, mentoring, and loyalty. This ruling ensures that inmates are not unfairly deprived of the opportunity to reduce their sentences based on good behavior, thereby upholding their rights to equal protection and humane treatment. The decision emphasizes that all inmates, regardless of when they were incarcerated, should be given the chance to rehabilitate and reintegrate into society, fostering fairness and justice within the correctional system.

From Behind Bars to Justice: Does Time Served Equate to Rights Earned?

This case revolves around a crucial question: Should the benefits of Republic Act (R.A.) No. 10592, which grants time allowances for good conduct to inmates, be applied retroactively? The petitioners, inmates of the New Bilibid Prison, argued that the law, which amends Articles 29, 94, 97, 98, and 99 of the Revised Penal Code (RPC), is penal in nature and beneficial to them. Thus, it should be given retroactive effect in accordance with Article 22 of the RPC, which states that penal laws favorable to the accused should be applied retroactively. The respondents, the Secretary of Justice and the Secretary of the Interior and Local Government, contended that Section 4, Rule 1 of the Implementing Rules and Regulations (IRR) of R.A. No. 10592 mandates a prospective application due to new procedures and standards. The central legal issue, therefore, is the validity of this IRR provision, which the inmates claim violates Article 22 of the RPC and their constitutional rights.

The Supreme Court, in its analysis, delved into the procedural and substantive aspects of the case. Initially, the Court addressed whether there was an actual case or controversy, legal standing, and the propriety of the legal remedy. Respondents argued that the case was not ripe for adjudication because the Management, Screening, and Evaluation Committee (MSEC) had not been constituted, and none of the petitioners had applied for the revised credits. However, the Court disagreed, citing the principle that an actual case exists when there is a conflict of legal rights that can be interpreted based on existing law and jurisprudence. It held that the challenged regulation had a direct adverse effect on the petitioners, who were currently incarcerated. The Court emphasized the urgency of the matter, stating that any delay in resolving the case would cause great prejudice to the prisoners. The High Court correctly observed that there was no need to wait for the actual organization and operation of the MSEC, as the mere issuance of the IRR had already led to a ripe judicial controversy, even without any other overt act.

In examining the issue of legal standing, the Court reaffirmed that the petitioners were directly affected by Section 4, Rule 1 of the IRR because they were prisoners serving sentences at the NBP. The outcome of the case would directly impact the length of their imprisonment. The Court dismissed the argument that the petitioners lacked legal standing because no GCTAs had been granted to them, explaining that the absence of GCTAs was a direct result of the prospective application of R.A. No. 10592, which was the very act being challenged. Furthermore, the Court addressed concerns about the propriety of the legal remedy, noting that while a petition for certiorari and prohibition might not be the appropriate remedy to assail the validity of the IRR due to its rule-making nature, such petitions are acceptable for raising constitutional issues and reviewing acts of legislative and executive officials. The Court underscored its duty to correct any grave abuse of discretion by any branch of the government, emphasizing the importance of resolving the validity of the IRR provision.

Moving to the substantive issues, the Supreme Court highlighted the significance of Article 22 of the RPC, which mandates the retroactive application of penal laws favorable to the accused. The Court recognized that R.A. No. 10592, while not defining a crime or prescribing a penalty, effectively diminishes the punishment attached to the crime. The further reduction in the length of imprisonment benefits both detention and convicted prisoners. Therefore, it necessitates the application of Article 22 of the RPC. The prospective application of the beneficial provisions of R.A. No. 10592 would work to the disadvantage of the petitioners. It would preclude the reduction in the penalty attached to their crimes and lengthen their prison stay. Thus, making the punishment for their offenses more onerous, and this directly violates the mandate of Article 22 of the RPC.

The respondents contended that new procedures and standards of behavior were necessary to fully implement R.A. No. 10592. They pointed to the substantial amendments and the need for a thorough revision of the BUCOR and BJMP operating manuals, particularly the establishment of the MSEC. However, the Court was not persuaded. Except for the benefits of TASTM and STAL granted to prisoners during calamities. The provisions of R.A. No. 10592 were mere modifications of the RPC that had already been implemented by the BUCOR before the issuance of the challenged IRR. The Court emphasized that good conduct time allowance had been in existence since 1906 with the passage of Act No. 1533, which provided for the diminution of sentences for good conduct and diligence. The definition of good conduct, in essence, remained invariable through the years. The MSEC creation does not justify the prospective application of R.A. No. 10592. The law does not set its formation as a precondition before applying its beneficial provisions.

Moreover, the Supreme Court found that the IRR’s directive for prospective application extended beyond the bounds of the legal mandate. The law only authorized the Secretaries of the DOJ and DILG to promulgate rules on the classification system for good conduct and time allowances, as necessary to implement the law’s provisions. The administrative and procedural restructuring, while intended to systematize existing set-ups, should not prejudice the substantive rights of current detention and convicted prisoners. As stated in the decision:

Indeed, administrative IRRs adopted by a particular department of the Government under legislative authority must be in harmony with the provisions of the law, and should be for the sole purpose of carrying the law’s general provisions into effect. The law itself cannot be expanded by such IRRSs, because an administrative agency cannot amend an act of Congress.

The Court noted that a Classification Board had been handling the functions of the MSEC and implementing the provisions of the RPC on time allowances. The Court also agreed with the petitioners that it was perplexing why it was complex for respondents to retroactively apply R.A. No. 10592 when all the MSEC had to do was utilize the same standard of behavior and refer to existing prison records. In its final ruling, the Supreme Court granted the consolidated petitions. It declared Section 4, Rule 1 of the IRR of R.A. No. 10592 invalid insofar as it provided for the prospective application of GCTA, TASTM, and STAL. The Court required the Director General of the Bureau of Corrections and the Chief of the Bureau of Jail Management and Penology to re-compute the time allowances due to the petitioners and all those similarly situated, and to cause their immediate release if they had fully served their sentences, unless they were confined for any other lawful cause.

FAQs

What was the key issue in this case?	The main issue was whether the Good Conduct Time Allowance (GCTA) law (R.A. No. 10592) should be applied retroactively, benefiting inmates incarcerated before its enactment, or only prospectively.
What did the Supreme Court decide?	The Supreme Court decided that the GCTA law should be applied retroactively, meaning that inmates who were incarcerated before the law’s enactment are also entitled to its benefits.
Why did the Court rule in favor of retroactive application?	The Court based its decision on Article 22 of the Revised Penal Code, which mandates that penal laws favorable to the accused should be applied retroactively.
What is the Good Conduct Time Allowance (GCTA)?	GCTA refers to time allowances granted to inmates for good behavior, participation in rehabilitation programs, study, teaching, mentoring, and loyalty, which can reduce their prison sentences.
What was the argument against retroactive application?	The government argued that the GCTA law should be applied prospectively due to new procedures and standards for granting time allowances and the creation of the MSEC.
What is the role of the Management, Screening, and Evaluation Committee (MSEC)?	The MSEC is responsible for managing, screening, and evaluating the behavior and conduct of inmates to determine their eligibility for time allowances under the GCTA law.
What does this ruling mean for current inmates?	This ruling means that current inmates, regardless of when they were incarcerated, are entitled to have their time allowances re-computed, potentially leading to earlier release dates.
Who is responsible for implementing this decision?	The Director General of the Bureau of Corrections and the Chief of the Bureau of Jail Management and Penology are responsible for re-computing time allowances and facilitating the release of eligible inmates.

In conclusion, the Supreme Court’s decision to apply the Good Conduct Time Allowance law retroactively marks a significant victory for inmates seeking fair and just treatment within the correctional system. The ruling affirms the principle that beneficial penal laws should be applied retroactively. The goal is to ensure that all prisoners, irrespective of when they began serving their sentences, have the chance to earn time allowances and reintegrate into society sooner, provided they demonstrate good behavior and a commitment to rehabilitation.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Inmates of the New Bilibid Prison vs. Sec. De Lima, G.R. No. 212719, June 25, 2019