Case: INMATES OF THE NEW BILIBID PRISON VS SEC DE LIMA- DOJ & SEC posed is ripe for adjudication

posed is ripe for adjudication as the challenged regulation has a direct adverse
ROXAS II- DILG l GR no. 212719 effect on the plaintiffs and other similarly situated prisoners.
Date: June 25, 2019 l Ponente: Peralta, J.: 6. The case involves a matter incapable of pecuniary estimation, falling under the
Subject: Characteristics of Penal Laws exclusive jurisdiction of the Regional Trial Court (RTC). However, due to
Sub-topic: exceptional circumstances and of national interest, the judicial policy allows for a
Digested by: Shiela Maquiling direct resort to the Supreme Court. The case has nationwide implications and
affects the entire correctional system of the Philippines.
7. The urgency to dispense substantive justice on the numerous affected inmates is
Doctrine: emphasized. The Court acknowledges the importance of protecting the right to
liberty and treats the case with leniency to give the plaintiffs the opportunity to
This features two consolidated cases in which prisoners of the New Bilibid Prison (NBP) are establish the merits of their case.
challenging the constitutional validity of the Implementing Rules and Regulations (IRR) of Issue:
Republic Act No. 10592. The prisoners argue that the IRR contradicts the law it implements by
1. Constitutional validity of the Implementing Rules and Regulations (IRR) of Republic
directing the prospective application of the grant of good conduct time allowance (GCTA),
Act No. 10592: The prisoners argue that the IRR contradicts the law it implements
time allowance for study, teaching and mentoring (TASTM), and special time allowance for
by directing the prospective application of the grant of good conduct time
loyalty (STAL). They argue that the provisions of R.A. No. 10592 are penal in nature and
allowance (GCTA), time allowance for study, teaching and mentoring (TASTM), and
beneficial to the inmates; hence, should be given retroactive effect in accordance with Article special time allowance for loyalty (STAL). They claim that this violates Article 22 of
22 of the Revised Penal Code. The case raises the issue of whether the IRR violates Article 22 the Revised Penal Code (RPC) which establishes retroactive effect for penal laws
of the Revised Penal Code by being prospective, rather than retroactive. The prisoners argue beneficial to the accused.
that the simple standards added by the new law, which are matters of record, and the 2. Violation of rights to liberty and due process: The prisoners argue that the simple
creation of the Management, Screening, and Evaluation Committee (MSEC) should not standards added by the new law, which are matters of record, and the creation of
override the constitutional guarantee of the rights to liberty and due process of law aside the Management, Screening, and Evaluation Committee (MSEC) should not
from the principle that penal laws beneficial to the accused are given retroactive effect. override the constitutional guarantee of the rights to liberty and due process of
law.
Facts:
The individual rulings in the case are as follows:
1. The case involves two consolidated cases filed by prisoners of the New Bilibid 1. Procedural Matters: The Court determines that there is an actual case or
Prison (NBP) challenging the constitutional validity of the Implementing Rules and controversy, as there is a contrariety of legal rights that can be interpreted and
Regulations (IRR) of Republic Act No. 10592. enforced based on existing law and jurisprudence. The legal issue posed is ripe for
2. The prisoners argue that the IRR contradicts the law it implements by directing the adjudication, and the challenged regulation has a direct adverse effect on the
prospective application of the grant of good conduct time allowance (GCTA), time petitioners and similarly situated detained prisoners. [4] [5a] [5b] [6]
allowance for study, teaching and mentoring (TASTM), and special time allowance 2. Propriety of legal remedy: Although the proper remedy to question the validity of
for loyalty (STAL). They argue that the provisions of R.A. No. 10592 are penal in the IRR would be a petition for declaratory relief filed before the Regional Trial
nature and beneficial to the inmates; hence, should be given retroactive effect in Court (RTC), the Court decides to entertain a direct resort to the Supreme Court
accordance with Article 22 of the Revised Penal Code. due to exceptional and compelling circumstances. The nationwide implications,
3. The case raises the issue of whether the IRR violates Article 22 of the Revised extensive scope, upholding of public policy, and repercussions on society warrant
Penal Code by being prospective, rather than retroactive. direct recourse to the Court, considering the urgent necessity to dispense
4. Respondents argue that the plaintiffs did not comply with all the elements of substantive justice to the numerous affected inmates.
justiciability, claiming that there is no actual case or controversy and that the 3. Substantive Issues: The Court addresses the substantive issues raised, particularly
claimed injury is premature or anticipatory. They argue that the prisoners filed the the retroactive or prospective application of the grant of GCTA, TASTM, and STAL.
case immediately after obtaining their prison records and computing the The Court acknowledges that every new law has a prospective effect, but Article
application of the revised credits for GCTA under R.A. No. 10592. 22 of the Revised Penal Code provides for retroactive application of penal laws
5. The Court disagrees and finds that there is an actual case or controversy as there is that are favorable or advantageous to the accused, unless the accused is a habitual
a contrariety of legal rights that can be interpreted and enforced based on existing criminal.
law and jurisprudence. The prisoners and intervenor’s view that the provision
violates the Constitution and Article 22 of the Revised Penal Code. The legal issue
 Therefore, the petition challenging the constitutionality of the IRR is
granted. The court recognizes the existence of an actual case or
controversy, as there is a contrariety of legal rights that can be
interpreted and enforced based on existing law and jurisprudence. The
court also concludes that the prisoners have standing to question the
validity of the IRR and that the issue of constitutionality is the very lis
mota (the essential issue) of the case. Additionally, the court finds that
the question raised is ripe for adjudication as the challenged regulation
has a direct adverse effect on the petitioners and other similarly
situated prisoners. Therefore, the court decides to proceed with the
substantive issues and resolves the question on the validity of Section
4, Rule 1 of the IRR.