CONSTITUTIONAL LAW II | INMATES OF THE NEW BILIBID PRISON VS. DE LIMA GR No. 212719, June 25, 2019

INMATES OF THE NEW BILIBID PRISON VS. DE LIMA 

GR No. 212719, June 25, 2019 


FACTS 

President Benigno S. Aquino III signed into law R.A. No. 10592, amending Articles 29, 94, 97, 98 and 99 of Act No. 3815, or the Revised Penal Code (RPC). Article 29 provides for the period of preventive imprisonment deducted from term of imprisonment, except when the accused is a 

recidivist and when upon being summoned for the execution of their sentence they have failed to surrender voluntarily. 

Petitioners contend that the provisions of R.A. No. 10592 are penal in nature and beneficial to the inmates, thus should be given retroactive effect in accordance with Article 22 of the RPC. For them, the IRR contradicts the law it implements. Petitioners submit that the simple standards added by the new law, should not override the constitutional guarantee of the rights to liberty and due process of law aside from the principle that penal laws beneficial to the accused are given retroactive effect. 

G.R. No. 214637, a Petition for Certiorari and Prohibition was filed by the petitioners who are all inmates at the Maximum Security Compound of the NBP, against the respondents. The grounds of the petition are as follows: (a) R.A. 10592 does not state that its provisions shall have prospective application, and (b) Section 4 of the IRR of R.A. 10592 is contrary to Article 22 of the Revised Penal Code providing that penal laws that are beneficial to the accused shall have retroactive application. 

ISSUE 

Whether or not Section 4, Rule 1 of the IRR of R.A. 10592 should be given retroactive application for the benefit of the accused person‟s right to liberty. 

RULING 

YES, Section 4, Rule 1 of the IRR of R.A. 10592 should be given retroactive application. 

An extended period of detention or one that is beyond the period allowed by law violates the accused person's right to liberty. The Court zealously guards against the curtailment of a person's basic constitutional and natural right to liberty. The right to liberty, which stands second only to life in the hierarchy of constitutional rights, cannot be lightly taken away. At its core, substantive due process guarantees a right to liberty that cannot be taken away or unduly constricted, except through valid causes provided by law. 

In the case at bar, the court held that the prospective application of the beneficial provisions of R.A. No. 10592 actually works to the disadvantage of petitioners and those who are similarly situated. It precludes the decrease in the penalty attached to their respective crimes and lengthens their prison stay, thus making more onerous the punishment for the crimes they committed. Depriving them of time off to which they are justly entitled as a practical matter results in extending their sentence and increasing their punishment. Evidently, this transgresses the clear mandate of Article 22 of the RPC.








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