G.R. No. L-26959 - Co vs. Commission on Elections

Oscar V. Co, the petitioner, and Cecilio O. Estoesta, the respondent, are both election registrar-appointees under the Commission on Elections (COMELEC).
The dispute centers on the assignment to different municipal stations which allegedly affects petitioner's security of tenure.

On November 2, 1964, COMELEC extended a provisional appointment to Oscar V. Co as "Election Registrar of the Commission on Elections" without specifying any particular station.
On November 9, 1964, by telegram-directive, Co was directed to report and assume duty as election registrar for Agoo, La Union, which he duly did.
On September 6, 1966, Co was given a permanent appointment as "Election Registrar in the Commission on Elections for Sabangan, Mountain Province" and was directed to immediately assume that post.
On September 7, 1966, Cecilio O. Estoesta was appointed as "Election Registrar in the Commission on Elections for Agoo, La Union." The appointment, which was duly certified by the Civil Service Commission and accepted by Estoesta, effectively caused a reassignment.

The petitioner argued that being reassigned from Agoo, La Union to Sabangan, Mountain Province violated his right to security of tenure.
He viewed the subsequent appointment of Estoesta to Agoo as infringing upon the rights allegedly conferred upon him by his initial appointment and service in Agoo.
Co asserted that his security of tenure depended on an appointment to a specific station, which he contended was undermined by the subsequent redirecting of his service.

The case primarily raises the issue of whether an appointment lacking a specific station confers security of tenure against subsequent assignment or reassignment.
The facts and arguments in this petition closely mirror those in Ibanez, et al. vs. Commission on Elections, et al., where similar issues on the nature of appointment versus assignment were addressed.
The court referenced earlier cases such as Miclat vs. Ganaden and Jaro vs. Valencia to highlight the distinction between appointments (with specific stations) and assignments (merely designating a duty location).

Whether, under the circumstances, the separate appointments and subsequent assignments infringe upon the petitioner's security of tenure as election registrar for Agoo, La Union.

Does a provisional or permanent appointment that does not specify a particular station create a vested right or guarantee security of tenure in that station?
Can the petitioner claim any right to the office of election registrar in Agoo, solely on the basis of his initial assignment, despite subsequent reassignments?

The issue directly addresses the legal distinction between appointment (the act of designating an officer to a specific post) and assignment (the directional deployment to fulfill official duties).
Whether or not the irregular formulation of the petitioner's appointment papers (i.e., absence of a specific station) precludes him from asserting a constitutional guarantee of security of tenure.