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EXPORT PROCESSING ZONE AUTHORITY v. COMMISSION ON HUMAN RIGHTS

FACTS:

On May 30, 1980, P.D. 1980 was issued reserving and designating certain parcels of land in Rosario and General Trias, Cavite, as the "Cavite Export Processing Zone" (CEPZ). The area was divided into Phases I to IV and a parcel in Phase IV was bought by Filoil Refinery Corporation, which was later sold to the Export Processing Zone Authority (EPZA). Before EPZA could take possession of the area, several individuals entered the premises and planted agricultural products without permission. In 1981, EPZA paid a financial assistance of P10,000 to those who accepted and signed quitclaims. Ten years later, on May 10, 1991, private respondents filed a joint complaint with the Commission on Human Rights (CHR), alleging various human rights violations. The CHR conducted an investigation and issued an injunction order commanding EPZA, the Philippine National Police (PNP), and Governor Remulla to desist from further acts of demolition, terrorism, and harassment. EPZA filed a motion to lift the injunction, but the Commission denied it. Consequently, the petitioner filed a special civil action of certiorari and prohibition with this Court.

ISSUES:

  1. Whether or not the Commission on Human Rights (CHR) has the authority to issue injunctive writs and temporary restraining orders.

  2. Whether or not the private respondents have a clear, positive right to be protected by an injunction.

  3. Whether or not the CHR abused its discretion in entertaining the private respondent's complaint.

  4. Whether or not the issues raised in the complaint had already been decided by the Court and thus barred by prior judgment.

RULING:

  1. The Court held that the CHR does not have the authority to issue injunctive writs and temporary restraining orders. The CHR's authority is limited to investigative and adjudicatory functions, and it cannot exercise judicial or quasi-judicial powers such as issuing injunctive orders.

  2. The Court did not directly rule on the issue of whether or not the private respondents have a clear, positive right to be protected by an injunction. However, it implied that the private respondents did not have a clear and positive right to be protected, as it emphasized that the CHR's jurisdiction is limited to human rights violations.

  3. The Court did not explicitly rule on whether or not the CHR abused its discretion in entertaining the private respondent's complaint. However, it implied that the CHR may have abused its discretion by entertaining the complaint, as it emphasized that the issues raised had already been decided by the Court and were thus barred by prior judgment.

  4. The Court held that the CHR cannot entertain the complaint because the issues raised had already been decided by the Court. It emphasized the principle of res judicata, which bars relitigation of issues that have already been decided with finality.

PRINCIPLES:

  • The CHR does not have the authority to issue injunctive writs and temporary restraining orders.

  • The CHR's jurisdiction is limited to investigating and adjudicating human rights violations.

  • The principle of res judicata bars the relitigation of issues that have already been decided with finality.