GR 121889; (August, 2000) (Digest)
G.R. No. 121889 ; August 4, 2000
P/Chief Supt. JEWEL F. CANSON, P/Sr. Supt. RUBEN CABAGNOT and P/Supt. JESUS L. ABAYON, petitioners, vs. HON. VICENTE A. HIDALGO, Presiding Judge, Regional Trial Court, Manila, Branch 37 and P/Sr. Inspector LUCIO MARGALLO IV, respondents.
FACTS
In April 1995, petitioner P/Chief Supt. Jewel F. Canson, as Regional Director, ordered the reassignment of respondent P/Senior Inspector Lucio Margallo IV from the Western Police District Command in Manila to the Regional Headquarters Support Group (RHSG) in Bicutan, Taguig. The purpose of the reassignment was for Margallo to undergo the Regional Continuing Law Enforcement Course (RECOLEC) program. Instead of complying, Margallo filed a petition for prohibition with preliminary injunction before the Regional Trial Court (RTC) of Manila, arguing the order was arbitrary and would place him in a “floating status,” rendering his special training useless.
The RTC, Branch 37, initially issued a temporary restraining order and, after a hearing, granted a writ of preliminary injunction. It enjoined the petitioners from enforcing the reassignment order. The petitioners had filed a motion to dismiss the petition, but the RTC issued its injunction order without first resolving this motion. The petitioners thus elevated the case to the Supreme Court via a petition for certiorari and mandamus.
ISSUE
Whether the Regional Trial Court acted with grave abuse of discretion in enjoining the reassignment of a police officer for the purpose of attending a continuing law enforcement course.
RULING
Yes, the trial court gravely abused its discretion. The Supreme Court ruled that the assignment and reassignment of officers within the Philippine National Police (PNP) is a management prerogative vested by law in the Chief of the PNP, which authority may be delegated through the chain of command. The courts have no supervisory power over the internal administration of the police force, and they cannot interfere with or restrain valid acts of police officials through injunction, absent a clear showing of grave abuse of discretion or action beyond their jurisdiction.
In this case, the reassignment order was a valid exercise of administrative discretion. It was not disciplinary in nature, as it involved no demotion, reduction in rank, or diminution of salary. On the contrary, it was intended for Margallo’s professional advancement by providing him with his first refresher course, which would benefit his career in the police hierarchy. Respondent Margallo possessed no clear legal right to remain in his specific post or to dictate his own assignment. Consequently, the RTC’s injunction constituted an unwarranted judicial intrusion into a legitimate administrative function of the PNP. The Supreme Court reversed the RTC decision and dismissed Margallo’s complaint.