G.R. No. 100150 January 5, 1994
BRIGIDO R. SIMON, JR., CARLOS QUIMPO, CARLITO ABELARDO, AND GENEROSO OCAMPO, petitioners, vs. COMMISSION ON HUMAN RIGHTS, ROQUE FERMO, AND OTHERS AS JOHN DOES, respondents.

FACTS

Petitioners, officials of the Quezon City Integrated Hawkers Management Council under the Office of the City Mayor, issued a “Demolition Notice” to private respondents, officers and members of the North EDSA Vendors Association, Inc., giving them three days to vacate their stalls along North EDSA to give way to the “People’s Park.” Private respondents filed a letter-complaint with the Commission on Human Rights (CHR), docketed as CHR Case No. 90-1580. The CHR issued an order directing petitioners to desist from the demolition pending resolution. After an ocular inspection and sworn statements convinced the CHR that the demolition was carried out on July 28, 1990, it issued a resolution ordering financial assistance for the vendors and again directed petitioners to desist, warning of contempt. Petitioners filed a motion to dismiss, questioning CHR’s jurisdiction, arguing the complainants were business entrepreneurs occupying government land and that the moratorium on demolitions applied only to poor dwellers, not vendors. They filed a supplemental motion to dismiss, contending the CHR’s authority is confined to investigating civil and political rights, not business privileges. The CHR denied the motions, cited petitioners in contempt for proceeding with the demolition despite the order, and imposed a fine of P500.00 each. Petitioners filed this petition for prohibition to stop the CHR from further hearing the case.

ISSUE

Whether or not the public respondent Commission on Human Rights has jurisdiction: a) to investigate the alleged violations of the “business rights” of the private respondents; b) to impose a fine of P500.00 each on the petitioners; and c) to disburse the amount of P200,000.00 as financial aid to the vendors.

RULING

The Supreme Court ruled that the Commission on Human Rights does not have the jurisdiction to investigate the case, impose the fine, or disburse financial aid. The CHR’s powers and functions under Section 18, Article XIII of the 1987 Constitution are specifically limited to investigating all forms of human rights violations involving civil and political rights. The rights allegedly violated in this case—the privilege to engage in business and the right to livelihood—are not civil and political rights. The Court, citing Cariño v. Commission on Human Rights, clarified that the CHR is not a quasi-judicial body with adjudicatory powers; its power is investigatory only, confined to fact-finding. It cannot issue restraining orders or injunctions, cite for contempt, or provide financial assistance, as these functions are adjudicatory and require judicial authority. The CHR’s order to desist, its citation for contempt with imposition of fines, and its directive for the disbursement of financial assistance were all issued without jurisdiction. The petition was granted, and the CHR was prohibited from further hearing CHR Case No. 90-1580.