EPZA vs. CHR

Export Processing Zone Authority vs. CHR
G.R. No. 101476, 14 April 1992

Facts

Certain parcels of land in Cavite were designated as Export Processing Zones by PD 1980. It was later sold to EPZA. Before the latter could take possession, several individuals planted agri products without permission from EPZA. EPZA paid P10k for them to sign quitclaims. Ten years later, 3 of those farmers filed with CHR a joint complaint praying for justice. CHR conducted an investigation. The farmers alleged that the Engineer of EPZA bulldozed their crops. They tried to stopped but the letter they showed was crumpled and they were insulted by the engineer’s team. In May 1991, CHR issued an order of injunction against EPZA, the PNP and Governor Remulla to desist from further acts of terrorism etc. Two weeks later, Governor Remulla and other men bulldozed the area, and allegedly handcuffed some of the farmers, and intimidated them. CHR Chairman again issued an injunction Order. EPZA filed with CHR a motion to lift the Order for CHR’s lack of authority. CHR denied and EPZA filed with the SC. SC issued a TRO ordering CHR to cease and desist implementing such injunction orders. CHR contended that Article 13 of the Constitution, its power is not limited to mere investigation but in letter c, “provide preventive measures and legal aid service to the underprivileged.”

Issue

Does the CHR have jurisdiction to issue a writ of injunction or TRO against the supposed violators of human rights? And to compel them to cease and desist from continuing the acts complained of?

Ruling

  • No. CHR is not a court of justice nor even a quasi-judicial body. (Cariño vs. CHR) It’s power is only to investigate, receive evidence and make findings of fact… but fact-finding is not adjudication nor a judicial function.”
  • The constitutional provision “provide preventive measures and legal aid service to the underprivileged” may not be construed to confer CHR with jurisdiction to issue TRO or writ of injunction. If that were the intention, the Constitution would have said so. Jurisdiction is conferred only by the Constitution or by law and never derived by implication (Garcia vs. De Jesus, Tobon Uy vs. COMELEC)
  • CHR’s power is only fact-finding, investigation, and receipt of evidence but not adjudication. Fact-finding is not adjudication. It must not be likened into the judicial function of a court of justice.

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