G.R. No. 81032 - Department of Education, Culture and Sports vs. Court of Appeals

On January 1, 1981, respondent Gloria V. Navarro was appointed as Secondary School Principal II by the Department of Education, Culture and Sports.
Her appointment did not specify any particular school; however, she was subsequently stationed at Carlos Albert High School.

In 1982, amid concerns that principals had been in one station for over five years, petitioner Edna B. Azurin, acting as Schools Division Superintendent of Quezon City, implemented a reshuffling of high school principals to address service exigencies.
As a result, Navarro was reassigned from Carlos Albert High School to Manuel Roxas High School, with no demotion in rank nor reduction in salary.
The reassignment was explicitly characterized as both a recognition of her proven administrative abilities and an opportunity for her to undertake new challenges.

On August 25, 1982, Navarro wrote a letter to petitioner Azurin requesting reconsideration of her transfer, citing her successful tenure at Carlos Albert High School.
Petitioner Azurin denied the request, explaining that:

The transfer was made in the exigencies of the service.
The reassignment was intended as a recognition of Navarro’s capabilities.
Having served for more than ten years in one station, Navarro was expected to bring her expertise to drive improvement at Manuel Roxas High School.

Despite denying her request, Navarro refused to comply with the lawful directive.
She escalated the matter by appealing to Regional Director Anastacio C. Ramento:

On October 6, 1982, Ramento issued a decision affirming the propriety of the transfer based on service exigencies.

Undeterred, Navarro submitted an appeal directly to Minister Onofre D. Corpuz on October 15, 1982.

On November 11, 1982, Corpuz issued a resolution denying her appeal, reiterating that the reassignment was lawful and within the superintendent’s prerogative.

Without exhausting administrative remedies by elevating the issue to the Civil Service Commission, Navarro filed a petition for Certiorari and Prohibition with a prayer for a preliminary injunction before the Regional Trial Court of Quezon City (Special Civil Action No. Q-37025).
A provisional order granting the issuance of the writ of preliminary injunction was issued on February 25, 1983.
Petitioner responded with an answer denying Navarro’s entitlement to the writ and arguing that:

Her reassignment was in conformity with the exigencies of service and did not constitute demotion.
It was implemented pursuant to MEC Circular No. 28, series of 1962.
Navarro had failed to exhaust administrative remedies as required.

Petitioner filed a Motion for Reconsideration regarding the preliminary injunction, which was denied.
An appeal was made to the Intermediate Appellate Court (docketed as AC-G.R. No. 01266) which rendered a decision setting aside the earlier provisional orders.
Despite the appellate decision, Civil Case No. Q-37025 continued until the petitioner moved for dismissal, contending that:

The issues had become moot and academic following the Intermediate Appellate Court’s resolution.
Navarro’s failure to appeal her reassignment to the Civil Service Commission rendered her petition without cause.

After successive hearings and motions (including an Opposition to Motion to Dismiss and a reply by petitioner), an order dismissing the civil case was issued on August 27, 1986, with a subsequent Motion for Reconsideration by Navarro denied on October 17, 1986.
On appeal (CA-G.R. SP No. 11305), the Court of Appeals eventually declared the earlier dismissal orders null and void, giving rise to the present recourse under review.

Whether the reassignment of Navarro from Carlos Albert High School to Manuel Roxas High School is valid given that her original appointment did not specify a particular school.

Whether the reassignment without Navarro’s consent contravenes Section 6 of Republic Act No. 4670 (the Magna Carta for Public School Teachers), which generally requires teacher consent for transfers except for cause or in certain exigencies.

Whether Navarro’s failure to exhaust available administrative remedies—specifically, by not appealing the transfer to the Civil Service Commission—affects her standing to challenge the reassignment in court.

Whether the justifications cited by petitioner Azurin (such as avoiding stagnation from long tenure and facilitating new administrative challenges) constitute sufficient ground to implement the reassignment under the exigencies of public service.