G.R. No. 81032 March 22, 1990
Department of Education, Culture and Sports, et al., petitioners, vs. The Honorable Court of Appeals and Gloria V. Navarro, respondents.

FACTS

Gloria V. Navarro was appointed Secondary School Principal II effective January 1, 1981, for the Division of City Schools, Quezon City. Her appointment did not specify a particular school station. For years, she was assigned as principal of Carlos Albert High School. In 1982, Schools Division Superintendent Edna B. Azurin implemented a reshuffling of high school principals in Quezon City, citing the exigencies of the service and a policy to reassign principals who had overstayed in one station for more than five years. Consequently, Navarro was reassigned to Manuel Roxas High School without any 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. She appealed administratively to Regional Director Anastacio Ramento and then to Minister Onofre Corpuz, both of whom upheld the transfer as lawful and within management prerogative. Without appealing further to the Civil Service Commission, Navarro filed a petition for certiorari and prohibition with the Regional Trial Court (RTC), which granted a preliminary injunction against the transfer. The DECS elevated the matter to the then Intermediate Appellate Court (IAC), which set aside the RTC’s orders, ruling the reassignment was valid. Upon remand, the RTC dismissed Navarro’s petition. However, the Court of Appeals reversed the RTC’s dismissal, applying the Magna Carta for Public School Teachers.

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. The legal logic proceeds from three key points. First, Navarro’s appointment was not to a specific school but to the division at large. A transfer or reassignment under such a circumstance is a management prerogative, exercised here for 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, not arbitrary, and was communicated to her. Her long tenure of over ten years at Carlos Albert made the reassignment ripe.
Second, the Magna Carta for Public School Teachers (RA 4670) does not absolutely prohibit transfers without consent. Section 6 of the law allows transfers “when made in the interest of the service.” The reassignment here, done without demotion or salary reduction and for a valid administrative purpose, falls squarely within this exception. The Court distinguished the inapplicability of prior rulings like Maderazo, which involved different factual circumstances.
Finally, 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. By bypassing this mandatory step and directly resorting to the RTC, Navarro’s petition was rendered without a cause of action. Therefore, the reassignment was lawful, and the RTC correctly dismissed her case.