G.R. No. 101476 - Export Processing Zone Authority vs. Commission on Human Rights

On May 30, 1980, P.D. 1980 reserved and designated certain parcels of land in Rosario and General Trias, Cavite as the "Cavite Export Processing Zone" (CEPZ).
The CEPZ was divided into Phases I to IV for developmental purposes.
A parcel in Phase IV was initially acquired by Filoil Refinery Corporation (formerly Filoil Industrial Estate, Inc.) and later sold to the Export Processing Zone Authority (EPZA).
Before EPZA could take possession of the area, several individuals entered the premises and began planting agricultural products without proper permission.
In 1981, to secure a peaceful departure, EPZA provided financial assistance amounting to P10,000 to the intruders who accepted and signed quitclaims. Among the beneficiaries were Teresita Valles and Alfredo Aledia (father of Loreto Aledia).

On March 20, 1991, EPZA Project Engineer, Engineer Neron Damondamon, accompanied by subordinates and members of the 215th PNP Company, brought heavy equipment (a bulldozer and a crane) to level the disputed area.

Private respondents attempted to halt the bulldozing by presenting a letter from the Office of the President ordering a postponement.
The letter was treated dismissively, being crumpled and thrown by a member of Damondamon’s group, who declared, “The President in Cavite is Governor Remulla!”

On April 3, 1991, media personnel covering the incident were physically assaulted; their cameras were snatched by PNP members and other government officials with civilian supporters.

On May 17, 1991, the CHR issued its first Order of Injunction compelling EPZA, the 125th PNP Company, Governor Remulla, and their subordinates to cease acts of demolition, harassment, and terrorism.

The order also mandated their appearance before the CHR on May 27, 1991, for a dialogue.

The same group, along with men from Governor Remulla’s entourage, bulldozed the area.
Teresita Valles was allegedly handcuffed, firearms were pointed at the other respondents, and a shot was fired in the air.

On May 28, 1991, CHR Chairman Mary Concepcion Bautista issued another injunction order.

This subsequent order reiterated and broadened the scope of the previous injunction.
It included additional government entities such as the Secretary of Public Works and Highways and contractors.
The expanded order prohibited further bulldozing and the destruction of irrigation canals pending the outcome of the investigation.

On July 1, 1991, EPZA filed a motion in the CHR to lift the injunction orders, which was later denied by the Commission on August 16, 1991.

On September 11, 1991, EPZA, represented by the Government Corporate Counsel, filed a special civil action for certiorari and prohibition in the Supreme Court.

The petition challenged the CHR’s injunction orders on grounds of lack of jurisdiction and grave abuse of discretion.
It also argued that the private respondents did not possess a clear, positive right to be protected by the injunction.
The petition contended that the issues had already been decided by the Court in prior judgment.

On September 19, 1991, the Supreme Court issued a temporary restraining order (TRO) against the CHR’s enforcement of its injunction orders.
The CHR, in its response, requested the lifting of the TRO and sought protection from further acts of demolition and harassment.
On November 14, 1991, the Solicitor General filed a manifestation and motion, emphasizing that the CHR’s earlier comment had fully addressed the issues raised in EPZA’s petition.

Whether the Commission on Human Rights, as a constitutional body mandated primarily for the investigation of human rights violations, possesses the authority to issue a writ of injunction or restraining order against alleged violators.
Whether the issuance of such injunctive orders infringes on the judicial power granted exclusively to courts.

Whether the fact-finding and investigative power of the CHR can be equated with adjudicative functions.
Whether by attempting to resolve issues on the merits of human rights violations, the CHR has ventured into territory that is constitutionally reserved for courts.

Whether the CHR’s injunction orders, including subsequent orders expanding the list of respondents, were correctly issued within the scope of its constitutional mandate.
Whether the preventive measures and legal aid services mandated by the Constitution can be interpreted as granting the CHR the power to issue direct injunctive relief.