Inmates of the New Bilibid Prison vs. De Lima, G.R. No.

212719, June 25, 2019

FACTS: On May 29,2013, President Aquino signed into law RA 10592 that amends Article
29,94,97,98 and 99 of the Revised penal. Immediately, pursuant to the amendatory law, an IRR
was jointly issued by the DOJ Secretary and the DILG Secretary. Petitioners and intervenors file
a Petition for Certiorari and Prohibition assailing the validity of Sec. 4, Rule 1 of the IRR that
directs the prospective application of the grant of good conduct allowance on the ground that it
violates Article 22 of the Revised Penal Code and violates the right to liberty provided in the
Constitution.

ISSUE: W/N Sec. 4 Rule 1 of the IRR violates the constitutional right to liberty.

HELD: Yes, There is an urgent necessity to dispense substantive justice on the numerous
affected inmates. It is a must to treat this consolidated case with a circumspect leniency, granting
petitioners the fullest opportunity to establish the merits of their case rather than lose their liberty
on the basis of technicalities. It need not be said that while this case has been pending, their right
to liberty is on the line. An extended period of detention or one that is beyond the period allowed
by law violates the accused person’s right to liberty. Hence, We shunt the rigidity of the rules of
procedure so as not to deprive such birthright. 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.