Case Digest (G.R. No. 100150) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Brigido R. Simon, Jr., et al. vs. Commission on Human Rights, et al., G.R. No. 100150, decided January 5, 1994, petitioners Brigido R. Simon, Jr. (Mayor of Quezon City), Carlos Quimpo, Carlito Abelardo, and Generoso Ocampo, all officers of the Quezon City Integrated Hawkers Management Council, served a Demolition Notice dated July 9, 1990, on members of the North EDSA Vendors Association, Inc., led by Roque Fermo. The Notice required private respondents to vacate North EDSA stalls by July 12, 1990, to make way for a proposed “People’s Park.” On July 12, 1990, the vendors filed a sworn complaint (Pinag-samang Sinumpaang Salaysay) before the Commission on Human Rights (CHR), docketed as CHR Case No. 90-1580, seeking intervention to stop the demolition. On July 23, 1990, the CHR ordered petitioners to “desist from demolishing” pending investigation and to appear before the Commission. Despite this, petitioners allegedly proceeded with demolition on July 28, 1990. On August 1, 19 Case Digest (G.R. No. 100150) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Origin of the Case
- Petitioners: Brigido R. Simon, Jr., Carlos Quimpo, Carlito Abelardo, and Generoso Ocampo—officials of the Quezon City Integrated Hawkers Management Council.
- Respondents: Commission on Human Rights (CHR), private complainants led by Roque Fermo (North EDSA Vendors Association), and others as John Does.
- Chronology of CHR Proceedings
- Demolition Notice (9 July 1990): Issued by petitioner Quimpo directing vendors to vacate North EDSA stalls within three days to make way for a “People’s Park.”
- Complaint to CHR (12 July 1990): Private respondents filed CHR Case No. 90-1580 alleging human rights violations; docketed by CHR.
- CHR Interim Orders:
- 23 July 1990 – Ordered petitioners to desist from demolition pending investigation and to appear before CHR.
- 1 August 1990 – Found demolition carried out on 28 July; ordered financial assistance of up to ₱200,000 for vendors; reiterated desist order with contempt warning.
- Motions to Dismiss Jurisdiction:
- 10 September 1990 – First motion challenging CHR’s jurisdiction over “business rights.”
- 18 September 1990 – Supplemental motion arguing CHR powers limited to civil and political rights.
- 21 September 1990 – Hearing of motions and contempt charge.
- Contempt Citation (25 September 1990): CHR fined each petitioner ₱500 for violating its desist order.
- Denial of Motions (1 March & 25 April 1991): CHR denied motions to dismiss and for reconsideration, asserting broad quasi-judicial powers to protect human rights including right to earn a living.
- Supreme Court Proceedings
- Petition for Prohibition (filed post-April 1991): Petitioners sought to prohibit CHR’s further proceedings in Case No. 90-1580, restrain enforcement of contempt fines, and prevent disbursement of financial aid.
- Temporary Restraining Order (18 June 1991): Supreme Court issued TRO directing CHR to cease and desist.
- Arguments on Jurisdiction: Solicitor General excused; CHR filed comment; private respondents defaulted.
Issues:
- Jurisdictional Scope of CHR
- Whether CHR may investigate alleged violations of “business rights” (vendors’ privilege to engage in commerce).
- Whether CHR may impose contempt fines (₱500 each) for non-compliance with its “desist” order.
- Whether CHR may disburse up to ₱200,000 as financial assistance to affected vendors.
- Justiciability and Remedies
- Whether the petition remains proper given subsequent developments (mootness).
- Proper scope of writ of prohibition against CHR.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)