Simon vs. Commission on Human Rights G.R. No. 100150 [January 5, 1994]

 CONSTITUTIONAL LAW

Simon vs. Commission on Human Rights

G.R. No. 100150 [January 5, 1994]

 EN BANC, VITUG, J.

 

Powers of Commission on Human Rights (CHR) to investigate civil and political rights violation of citizen; 

The Commission on Human Rights (CHR) is limited to investigating violations of civil and political rights, as defined by the Constitution. Economic rights and privileges, such as the right to engage in business, do not fall under the CHR’s jurisdiction unless they are directly linked to civil or political rights violations. Furthermore, the CHR’s contempt powers are confined to enforcing compliance with its investigative mandates and cannot be used to enforce orders in matters outside its constitutional authority.

 

In July 1990, the Quezon City government issued a demolition notice to vendors occupying stalls and shanties along North EDSA. The notice, signed by petitioner Carlos Quimpo, instructed the private respondents—members of the North EDSA Vendors Association—to vacate the premises within three days to make way for the development of a “People’s Park.” The respondents sought assistance from the Commission on Human Rights (CHR), filing a complaint to stop the demolition. 

The CHR issued several orders to halt the demolition and provide financial assistance to the affected vendors. It also cited the petitioners for contempt when the demolition proceeded despite its directives. The petitioners challenged the CHR’s jurisdiction, arguing that the issues raised did not fall under human rights violations involving civil or political rights as envisioned by the Constitution. They claimed that the respondents’ rights to engage in business were merely privileges, not enforceable human rights.

 

Whether or not the CHR have jurisdiction to investigate the demolition of vendors’ stalls and shanties as a human rights violation involving civil and political rights. 

NO. The Supreme Court ruled that the CHR’s jurisdiction is confined to investigating violations of civil and political rights and that it exceeded its authority in this case. The Court invalidated the CHR’s orders to stop the demolition and its imposition of contempt penalties. 

The Court explained that civil rights pertain to an individual’s entitlements as a citizen, such as property rights, equal protection under the law, and contractual freedom. Political rights relate to participation in governmental functions, such as suffrage and holding public office. Human rights violations, as contemplated by the Constitution, are those involving severe breaches of civil and political rights, such as torture, enforced disappearances, or political detention. 

The Court found that the demolition of stalls and shanties, planned for the construction of a public park, did not constitute a human rights violation involving civil or political rights. The claimed “right to engage in business” was a mere privilege and not among the inalienable rights protected under the CHR’s jurisdiction. 

On the CHR’s power to cite for contempt, the Court held that this authority is limited to enforcing its operational guidelines and rules of procedure necessary to carry out its investigative function. The CHR’s contempt powers do not extend to enforcing resolutions on matters beyond its jurisdiction, such as halting a demolition based on alleged economic rights violations.

 

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