FACTS:

In this case, a demolition notice was sent to the officers and members of the North EDSA Vendors Association. The vendors filed a complaint with the CHR, asking for the demolition to be stopped. The CHR issued an order directing the petitioners to desist from demolishing the stalls and shanties and subsequently ordered the disbursement of financial assistance to the vendors. The petitioners filed a motion to dismiss, questioning the jurisdiction of the CHR. The motion argued that the complaint was not within the CHR's jurisdiction as the complainants were independent business entrepreneurs and not poor dwellers. The motion to dismiss was denied by the CHR.

The case involves a petition challenging the jurisdiction of the Commission on Human Rights (CHR) to investigate alleged violations of the "business rights" of the petitioners. The petitioners demolished stalls at the instance and authority given by the Mayor of Quezon City, which affected vendors. The petitioners argue that the CHR does not have jurisdiction to investigate the alleged violations, impose fines, and disburse financial aid to the affected vendors. The CHR claims that its investigative power includes investigating human rights violations involving civil and political rights. The Supreme Court is tasked with determining the extent of the CHR's investigative power and whether it has jurisdiction in this case.

The case begins with a discussion on the definition of "human rights," with various answers provided. The Universal Declaration of Human Rights is mentioned, suggesting that human rights include aspects related to an individual's social, economic, cultural, political, and civil relations. The case then raises the question of whether the framers of the 1986 Constitution and the independent commission created to safeguard human rights had these broad concepts in mind. The case refers to the country's experience under the martial law regime, where constitutional rights were suspended, and the violation of human rights that ensued.

ISSUES:

1. Whether the framers of the 1986 Constitution contemplated the broad concepts of human rights that include social, economic, cultural, political, and civil relations.

2. Whether the provisions on human rights in the Constitution and the creation of an independent commission to safeguard these rights were influenced by the martial law regime.

3. • Whether the concept of human rights should be limited to political rights or should include other rights such as social and economic rights
4. • Whether the proposed Commission on Human Rights should have a broad or limited jurisdictional area

5. Whether the Commission on Human Rights (CHR) has jurisdiction over cases involving the demolition of private structures and its powers to issue restraining orders.

6. Whether the demolition of the stalls, sari-sari stores, and carinderia falls within the scope of "human rights violations involving civil and political rights" under the Constitution.

7. Whether or not the Commission on Human Rights (CHR) has jurisdiction to issue a writ of preliminary injunction.

8. Whether or not the petitioners have standing to question the disbursement of financial aid.

9. Whether or not the petition for prohibition has become moot and academic.

RULING:

1. The court did not provide a specific ruling on the issues mentioned.

2. • The concept of human rights should be limited to political rights. The Commission on Human Rights has a limited jurisdictional area, specifically in areas related to political crimes and violations.

3. The CHR does not have jurisdiction to issue a restraining order or writ of injunction. The power to cite for contempt applies only to violations of its adopted operational guidelines and rules of procedure essential to carry out its investigatorial powers.

4. The demolition of the private structures does not fall within the compartment of "human rights violations involving civil and political rights" intended by the Constitution.

5. The CHR does not have jurisdiction to issue a writ of preliminary injunction. The writ can only be issued by a judge of a court in which the action is pending, or a Justice of the Court of Appeals or the Supreme Court. The CHR is not a court of justice and the writ is an ancillary remedy available only in a pending principal action.

6. The petitioners lack locus standi to question the disbursement of financial aid. The issue is within the jurisdiction of the appropriate administrative agencies concerned to initially consider.

7. The petition for prohibition is not moot and academic. Prohibition is a preventive remedy to restrain an act about to be done and can be used to prevent the CHR from resolving CHR Case No. 90-1580. The writ is granted and the CHR is prohibited from further proceeding with the case and implementing the fine for contempt.

PRINCIPLES:

• The Covenant on Civil and Political Rights suggests that human rights encompass almost all aspects of life.

• The Constitution of 1935 and 1973 enshrined most of the human rights expressed in the International Covenant, but these rights were rendered unavailable during martial law.

• The primacy of the task of the Commission on Human Rights (CHR) in safeguarding human rights must be made clear.

• Civil and political rights are broad and every single right of an individual can be considered a civil or political right.

• The CHR's task is to defend specific rights enshrined in international documents and legal instruments, such as the right to life, the right against torture, and the right to fair and public hearing.

• Other violations of citizens' rights can be addressed to the proper courts and authorities.

• The CHR's jurisdiction does not include cases under the ordinary investigative and prosecutorial agencies of the government, unless they pertain to civil and political rights.

• The specific parameters of civil and political rights must cover the international standards governing the behavior of governments regarding the political and civil rights of citizens, especially political detainees or prisoners.

• The concept of human rights can be limited to political rights, with the understanding that other rights may be included in the future.

• The Commission on Human Rights should have a clear and specific jurisdictional area.

• Civil rights refer to rights that belong to every citizen and are not connected with the organization or administration of government.

• Political rights refer to the right to participate in the establishment or administration of government.

• The Commission on Human Rights (CHR) is empowered to investigate human rights violations involving civil and political rights.

• The CHR has no jurisdiction to issue restraining orders or writs of injunction.

• The power to cite for contempt by the CHR applies only to violations of its adopted operational guidelines and rules of procedure.

• The "preventive measures and legal aid services" mentioned in the Constitution refer to remedies that the CHR may seek from courts on behalf of victims of human rights violations.

• The CHR does not have jurisdiction to issue a writ of preliminary injunction.

• Locus standi is required to question the disbursement of financial aid.

• Prohibition is a preventive remedy to restrain an act about to be done.