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.
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