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INMATES OF NEW BILIBID PRISON v. DOJ - CRIMINAL LAW CASE DIGEST

 



INMATES OF NEW BILIBID PRISON v. DOJ

G.R. No. 212719, June 25, 2019

PERALTA, J.:


TOPICS: WHAT IS A PENAL LAW?

                 RETROACTIVE EFFECT OF PENAL LAWS


FACTS:

Then President Benigno Aquino III signed into law R.A. No. 10592 amending Articles 29, 94, 97, 98, and 99 of the Revised Penal Code.  An IRR was jointly issued by DOJ and DILG.  Petitioners and intervenors assails the validity of its Section 4, Rule 1 that directs the prospective application of the grant of good conduct time allowance, time allowance for study, teaching and mentoring, and special time allowance for loyalty mainly on the ground that it violates Article 22 of the Revised Penal Code.

ISSUE:

What is a penal law?

Should R.A. No. 10592 should be given retroactive effect?

HELD:

The Supreme Court defined penal law as, "those acts of the Legislature which prohibit certain acts and establish penalties for their violation; or those that defines crimes, treat their nature, and provide for their punishment"

Yes, R.A. No. 10592 should be given retroactive effect.

Article 22 of the Revised Penal Code provides that, "Penal laws shall have retroactive effect insofar as they favor the person guilty of a felony, who is not a habitual criminal, as this term is defined in Rule 5 of Article 62 of this Code, although at the time of the publication of such laws a final sentence has been pronounced and the convict is serving the same"

The Supreme Court held that while R.A. No. 10592 does not define a crime/offense or provide/prescribe/establish a penalty as it addresses the rehabilitation component of our correctional system, its provisions have the purpose and effect of diminishing the punishment attached to the crime.  the further reduction on the length of the penalty of imprisonment is, in the ultimate analysis, beneficial to the detention and convicted prisoners alike; hence, calls for the application of Article 22 of the Revised Penal Code.


Read Full Text : Inmates of New Bilibid Prison v. DOJ Secretary (full text) - ChanRobles

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