G.R. No. 101476 April 14, 1992
EXPORT PROCESSING ZONE AUTHORITY, petitioner, vs. THE COMMISSION ON HUMAN RIGHTS, TERESITA VALLES, LORETO ALEDIA and PEDRO ORDONEZ, respondents.

FACTS

On May 30, 1980, a parcel of land in Cavite was designated as the Cavite Export Processing Zone (CEPZ). A portion of this area, later acquired by the Export Processing Zone Authority (EPZA), was occupied by several individuals, including the private respondents, who planted agricultural products without permission. In 1981, EPZA paid financial assistance to some occupants, including the father of respondent Loreto Aledia and respondent Teresita Valles, who signed quitclaims.
On May 10, 1991, the private respondents filed a complaint with the Commission on Human Rights (CHR), alleging human rights violations. They claimed that on March 20, 1991, EPZA’s project engineer, accompanied by police and using heavy equipment, attempted to bulldoze the area they occupied, disregarding a letter from the Office of the President ordering postponement. Further incidents on April 3, 1991, involved alleged assaults on mediamen. On May 17, 1991, the CHR issued an Order of injunction against EPZA, the police, and Governor Remulla to desist from demolition, terrorism, and harassment. Despite this, bulldozing allegedly continued on May 25, 1991. Consequently, on May 28, 1991, the CHR issued another injunction order, expanding it to include the Secretary of Public Works and Highways and contractors.
EPZA filed a motion to lift the injunction, arguing the CHR lacked authority to issue such writs. The CHR denied the motion. EPZA then filed a petition for certiorari and prohibition with the Supreme Court, alleging the CHR acted in excess of jurisdiction and with grave abuse of discretion. The Supreme Court issued a temporary restraining order against the CHR on September 19, 1991.

ISSUE

Does the Commission on Human Rights have jurisdiction to issue a writ of injunction or restraining order against supposed violators of human rights?

RULING

No. The Supreme Court GRANTED the petition. The orders of injunction dated May 17 and 28, 1991, issued by the CHR were ANNULLED and SET ASIDE, and the Supreme Court’s temporary restraining order was made PERMANENT.
The Court held that the CHR is not a court of justice nor a quasi-judicial body. Its constitutional power is limited to investigation, i.e., receiving evidence and making findings of fact regarding human rights violations involving civil and political rights. Fact-finding is not adjudication. The CHR does not have the authority to apply the law to factual conclusions to decide controversies authoritatively. The constitutional mandate for the CHR to “provide for preventive measures and legal aid services” does not confer jurisdiction to issue restraining orders or injunctions. Such jurisdiction is conferred only by the Constitution or by law and cannot be derived by implication. The “preventive measures” refer to extrajudicial and judicial remedies, including preliminary injunctions, which the CHR may seek from the proper courts on behalf of victims. A writ of preliminary injunction is an ancillary remedy available only in a pending principal action before a court. Since the CHR is not a court, it lacks the jurisdiction to issue such writs.