G.R. No. 113843 June 2, 1995
HON. LIWAYWAY VINZONS-CHATO, in her capacity as Commissioner of Internal Revenue, and SOLON B. ALCANTARA, petitioners, vs. HON. ELI G.C. NATIVIDAD, Presiding Judge of Branch 48, Regional Trial Court of San Fernando, Pampanga, and SALVADOR NORI B. BLAS, respondents.

FACTS

Pursuant to Executive Order No. 132 streamlining the Bureau of Internal Revenue (BIR), Commissioner Liwayway Vinzons-Chato issued Revenue Travel Assignment Order No. 80-93, reassigning numerous Revenue District Officers (RDOs) nationwide. Private respondent Salvador Nori Blas, the RDO of San Fernando, Pampanga, was ordered transferred to Tuguegarao, Cagayan. Blas requested reconsideration, arguing his transfer was a demotion as his former district was larger and had a higher classification than his new assignment. He also cited personal health reasons. His request unacted upon, Blas filed an injunction suit in the Regional Trial Court (RTC), alleging the transfer violated E.O. No. 132’s provision that redeployment shall not result in dislocation or diminution of rank. The RTC granted a writ of preliminary injunction, ordering the Commissioner to cease enforcing the transfer order against Blas pending trial.

ISSUE

Whether the respondent judge committed grave abuse of discretion in issuing the writ of preliminary injunction enjoining Blas’s reassignment.

RULING

Yes, the Supreme Court granted the petition and annulled the RTC’s order. The legal logic is clear: a preliminary injunction requires a clear and unmistakable right to be protected. Blas failed to establish such a right. First, as a mere designated (not appointed) RDO, he had no vested right to remain at a specific station. Transfers are a management prerogative, especially when done pursuant to a valid reorganization in the interest of public service. Second, his claim of demotion was unfounded. The very administrative order implementing the reorganization abolished the previous classification of RDOs into Classes A, B, C, etc., and established that all RDOs were of the same class. Therefore, any perceived diminution based on the old classification system was illusory and legally baseless. The transfer did not involve a reduction in rank, status, or salary. The RTC’s issuance of the injunction, based on a supposed need for a full trial on these settled legal points, constituted grave abuse of discretion. The Court also found no merit in Blas’s subsequent contempt motions against the Commissioner for pursuing administrative cases against him, as those were separate from the validity of the transfer order.