G.R. No. 81032 March 22, 1990
DEPARTMENT OF EDUCATION, CULTURE AND SPORTS, represented by EDNA V. AZURIN, ANASTACIO RAMENTO and HON. ONOFRE D. CORPUS, petitioners, vs. THE HONORABLE COURT OF APPEALS and GLORIA V. NAVARRO, respondents.

FACTS

Respondent Gloria V. Navarro was appointed Secondary School Principal II effective January 1, 1981. Her appointment did not specify a particular school, stating only her assignment to the Division of City Schools, District II, Quezon City. For years, she was stationed at Carlos Albert High School. In 1982, petitioner Edna B. Azurin, as Schools Division Superintendent, effected a reshuffling of high school principals in Quezon City, citing the exigencies of the service and the fact that principals, including Navarro who had served for over ten years at one station, had overstayed beyond five years. Navarro was reassigned to Manuel Roxas High School without demotion in rank or diminution in salary.
Navarro requested reconsideration, which was denied. She then refused to comply, arguing her transfer violated the Magna Carta for Public School Teachers (RA 4670) as it was without her consent. After her appeals were denied by higher education officials, she filed a petition for certiorari and prohibition with the Regional Trial Court (RTC) without first appealing to the Civil Service Commission. The RTC initially granted a preliminary injunction. The Intermediate Appellate Court later set aside this injunction, ruling the reassignment was valid. The RTC subsequently dismissed Navarro’s petition. On Navarro’s appeal, the Court of Appeals reversed the RTC’s dismissal, applying the Magna Carta for Public School Teachers. The petitioners elevated the case to the Supreme Court.

ISSUE

Whether the reassignment of Gloria Navarro from Carlos Albert High School to Manuel Roxas High School is valid.

RULING

Yes, the reassignment is valid. The Supreme Court reversed the Court of Appeals decision. The legal logic rests on three key points. First, Navarro’s appointment was not to a specific school but to a division. A transfer or reassignment within the same division, without a change in rank or salary, is a management prerogative exercised in the interest of public service. Second, the reassignment complied with the exigencies of the service. The reason—to prevent principals from becoming “stale” after over five years in one station and to avoid over-fraternization detrimental to the service—was substantial, factual, and not whimsical. Navarro’s lengthy ten-year stay made her ripe for reassignment. The Magna Carta for Public School Teachers (RA 4670) does not prohibit transfers made in the exigencies of the service. Third, Navarro failed to exhaust administrative remedies. Under the Civil Service Decree (PD 807), an employee who believes a transfer is unjustified must appeal to the Civil Service Commission before resorting to judicial action. By filing her court petition directly, Navarro had no cause of action. Therefore, her reassignment was lawful and her petition was correctly dismissed by the RTC.