CASE DIGEST : INMATES OF THE NEW BILIBID PRISON, MUNTINLUPA CITY VS SECRETARY LEILA M. DE LIMA June 25, 2019 G.R. No. 212719

FACTS : R.A. No. 10592, enacted on May 29, 2013, amended Articles 29, 94, 97, 98, and 99 of the Revised Penal Code by expanding the benefits granted to qualified prisoners, including Good Conduct Time Allowance (GCTA), Time Allowance for Study, Teaching and Mentoring (TASTM), and Special Time Allowance for Loyalty (STAL). It increased the deductions from prison sentences for good behavior, extended these benefits to qualified detention prisoners, allowed additional deductions for study, teaching, and mentoring, and provided that time allowances, once granted, cannot be revoked. Pursuant to the law, the DOJ and DILG issued the Implementing Rules and Regulations (IRR), which took effect on April 18, 2014. However, Section 4, Rule I of the IRR limited the application of these benefits to a prospective basis.

Several inmates and their representatives challenged the validity of the IRR before the Supreme Court through petitions for certiorari and prohibition, arguing that Section 4, Rule I was ultra vires, unconstitutional, and contrary to Article 22 of the Revised Penal Code, which mandates the retroactive application of penal laws favorable to the accused, provided they are not habitual criminals. The petitioners, including Roxas et al., Edago et al., and intervenors represented by Atty. Rene Saguisag and the Free Legal Assistance Group (FLAG), maintained that R.A. No. 10592 is a penal law beneficial to prisoners, contains no provision limiting its application to future convictions, and that the IRR unlawfully deprived inmates already serving sentences of the benefits intended by Congress. They likewise argued that the prospective application violated the equal protection and due process clauses of the Constitution by arbitrarily distinguishing between prisoners based solely on the date the law took effect.

The Office of the Solicitor General, on behalf of the respondents, filed comments defending the validity of the IRR, while the petitions were consolidated before the Supreme Court for resolution. The central issue raised was whether the IRR's prospective application of R.A. No. 10592 was valid, or whether the law should instead be retroactively applied pursuant to Article 22 of the Revised Penal Code, allowing qualified inmates already serving sentences before the law's enactment to benefit from the expanded sentence deductions.

ISSUE : WON the CA is COrrect

HELD : The Supreme Court held that there was an actual case or controversy because the petitioners, who were inmates, were directly affected by Section 4, Rule I of the Implementing Rules and Regulations (IRR) of Republic Act No. 10592, which limited the grant of Good Conduct Time Allowance (GCTA), Time Allowance for Study, Teaching and Mentoring (TASTM), and Special Time Allowance for Loyalty (STAL) to prospective application. The Court ruled that the issue was ripe for judicial determination since the IRR itself already posed an immediate threat to the inmates' right to liberty, making it unnecessary for them to first apply for the benefits or await the creation of the Management, Screening and Evaluation Committee (MSEC). The petitioners likewise had legal standing because the challenged IRR directly affected the duration of their imprisonment. Although certiorari and prohibition are generally improper remedies against quasi-legislative acts, the Court entertained the petitions due to the transcendental importance of the issues, the public interest involved, and the urgent need to protect the constitutional right to liberty.

On the merits, the Court declared Section 4, Rule I of the IRR invalid for being inconsistent with Article 22 of the Revised Penal Code (RPC), which mandates the retroactive application of penal laws favorable to the accused, provided the offender is not a habitual criminal. While R.A. No. 10592 does not define crimes or prescribe penalties, the Court held that it effectively reduces the period of imprisonment by increasing time allowances, thereby diminishing the punishment imposed and making it a favorable penal law. The Court emphasized that administrative agencies cannot amend, restrict, or expand the law they are tasked to implement, and the DOJ and DILG exceeded their authority by limiting the law's application to future prisoners when Congress imposed no such limitation. Accordingly, the Bureau of Corrections (BuCor) and the Bureau of Jail Management and Penology (BJMP) were ordered to retroactively recompute the time allowances of qualified inmates and immediately release those who had already fully served their sentences, unless they were lawfully detained for another cause.

CASE DIGEST : ROBERTO S. BENEDICTO and HECTOR T. RIVERA, petitioners, vs. THE COURT OF APPEALS G.R. No. 125359 September 4, 2001

FACTS : Between December 1991 and January 1992, Imelda Marcos, Roberto Benedicto, and Bienvenido Rivera were charged in numerous criminal cases for violating Section 10 of Central Bank Circular No. 960 in relation to Section 34 of Republic Act No. 265 (Central Bank Act). The Informations alleged that they maintained and earned income from unauthorized foreign exchange accounts abroad through foreign banks and dummy foundations, but failed to report or register these foreign exchange earnings with the Central Bank as required by Circular No. 960. The cases involved several foreign accounts, large sums of money, and were consolidated before the Regional Trial Court of Manila.

While the cases were pending, the Central Bank issued Circular Nos. 1318 and 1353, which liberalized foreign exchange regulations and effectively repealed many of the restrictions under Circular No. 960. However, both circulars expressly contained saving clauses preserving pending criminal cases for violations of Circular No. 960. After arraignment, the accused moved to quash the Informations, arguing, among others, lack of jurisdiction, prescription, repeal of Circular No. 960 resulting in the extinction of criminal liability, exemption from the reporting requirement, and immunity under a compromise agreement with the government. The trial court denied the motions, prompting the accused to file petitions for certiorari and prohibition before the Court of Appeals. The Court of Appeals upheld the trial court’s rulings and dismissed the petitions, except for Criminal Case No. 91-101884, which it ordered dismissed.

ISSUE : WON the CA is correct

HELD : The Supreme Court affirmed the RTC’s jurisdiction over the criminal cases, holding that under P.D. No. 1606, offenses punishable by imprisonment of not more than five years, such as violations of Central Bank Circular No. 960 in relation to Section 34 of R.A. No. 265 (Central Bank Act), fall within the jurisdiction of the Regional Trial Court, not the Sandiganbayan. The Court also ruled that forum shopping did not exist because the RTC cases involved failure to report foreign exchange earnings under Circular No. 960, while the Sandiganbayan cases involved prohibited transactions under R.A. No. 3019 (Anti-Graft and Corrupt Practices Act)—distinct offenses arising from the same facts but punishable under different laws. Petitioners likewise waived any defect in the preliminary investigation by posting bail, entering their pleas, and actively participating in the proceedings without timely insisting on a proper preliminary investigation, consistent with the rule that such right is statutory and waivable.

The Court further held that the repeal of Central Bank Circular No. 960 and R.A. No. 265 did not extinguish petitioners’ criminal liability. Although Circular No. 960 was repealed by Circular Nos. 1318 and 1353, both contained saving clauses preserving pending criminal actions. Likewise, while R.A. No. 7653 (New Central Bank Act) repealed R.A. No. 265, it simultaneously reenacted the penal provisions under Section 36, thereby preserving liability for acts previously penalized. The Court also rejected the claim that Section 36 constituted an ex post facto law, ruling that penal statutes operate prospectively absent a clear legislative intent to apply them retroactively. Furthermore, the offenses had not prescribed under Act No. 3326, as the eight-year prescriptive period commenced only upon the discovery of the violations after the 1986 EDSA Revolution, when the government first uncovered the concealed foreign exchange accounts.

The Court likewise rejected petitioners’ claim that they were exempt from the reporting requirements of Circular No. 960. The exemption under Section 10(q) of Circular No. 960, in relation to R.A. No. 6426 (Foreign Currency Deposit Act), applies only to foreign currency deposits maintained in designated Philippine banks, whereas petitioners’ accounts were held in foreign banks. Their reliance on Swiss banking secrecy laws also failed because foreign laws must be pleaded and proved, which petitioners did not do. Finally, the Court ruled that the Compromise Agreement between Roberto Benedicto and the government did not grant immunity from prosecution in these cases, as the agreement expressly covered only specified sequestration and ill-gotten wealth cases and did not include the criminal prosecutions for violations of Circular No. 960. Accordingly, the petition was dismissed, with the sole modification that the criminal cases against Roberto Benedicto were ordered dropped and his criminal and civil liability ex delicto extinguished due to his death before final judgment, pursuant to the Revised Penal Code.