MANILA, Philippines: The Supreme Court found that the Department of Justice (DoJ) exceeded its power of subordinate legislation when it excluded persons convicted of heinous crimes from the benefits of Republic Act (RA) 10592, or the New Good Conduct Time Allowance (GCTA) law.
In finding the assailed provisions of the 2019 Implementing Rules and Regulations (2019 IRR) invalid, the High Court en banc, through Associate Justice Maria Filomena Singh, held that when RA 10592 amended Article 97 of the Revised Penal Code (RPC), it used the connecting conjunction "or" to express that "any offender qualified for credit imprisonment pursuant to Article 29 of the RPC," and in the alternative "any convicted prisoner in any penal institution, rehabilitation, or detention center in any other local jail" may avail of the benefits granted by RA 10592.
Thus, the Court ruled the 2019 IRR expanded the scope of RA 10592 when it excluded recidivists, habitual delinquents, escapees, and persons deprived of liberty convicted of heinous crimes from earning GCTA credits when the law itself did not do so.
The Court ruled that Article 97 of the RPC, as amended by RA 10592, was clear that any convicted prisoner would be entitled to GCTA as long as the prisoner was in any penal institution, rehabilitation or detention center, or any other local jail.