G.R. No. 93711 - Marohombsar vs. Alonto, Jr.

On March 22, 1988, the petitioner, Dr. Emily M. Marohombsar, was designated as Officer-in-Charge of the Office of the Vice-Chancellor for Academic Affairs (OVCAA) of MSU Marawi Campus, concurrently holding her permanent post as Vice-President for External Studies.
On January 2, 1989, the Office of the Vice-President for External Studies was merged with the OVCAA. On the same day, she was appointed acting Vice-Chancellor for Academic Affairs.
The Board of Regents of MSU confirmed her appointment as acting Vice-Chancellor for Academic Affairs on May 16, 1989 by Resolution No. 59, S. 1989.

On May 14, 1990, the MSU President, Ahmad E. Alonto, informed the petitioner of his decision to tap her talent for the MSU system by offering her the position of Vice-President for Academic Affairs, a role under his direct administrative control.
The petitioner refused the new position, preferring to continue projects initiated in her current role.
On May 16, 1990, the respondent President designated another individual, Professor Macacuna Moslem, as Vice-Chancellor for Academic Affairs; however, Moslem did not accept the appointment.
On May 28, 1990, a further administrative move was made when the respondent President issued Special Order No. 158-P, appointing Professor Corazon Batara as Officer-in-Charge of the OVCAA.

The petitioner assailed her removal from the office of acting Vice-Chancellor for Academic Affairs, contending that her appointment was permanent and could be revoked only through due process (for cause and after a hearing).
On June 21, 1990, the Court issued a temporary restraining order to prevent the enforcement or implementation of Special Order No. 159-P and to stop any interference with the petitioner’s duties.
On November 19, 1990, the petitioner filed a motion to cite respondent Alonto for contempt, alleging that his actions—specifically, submitting Special Order No. 158-P for Board approval after the restraining order—were in violation of the Court’s order.

The petitioner’s permanent status as a career official and Professor VI of MSU, with over 27 years of service, constituted a factor in her claim that her appointment should retain the benefits and security of tenure inherent in a permanent office.
A series of acting appointments in the MSU Board of Regents meeting further illustrated a broader scheme where top administrative positions were converted into roles serving at the pleasure of the President and, by extension, the Board, thereby undermining the security of tenure.

The central issue was whether the petitioner, appointed as acting Vice-Chancellor for Academic Affairs, could be removed from office without due process, particularly in the absence of cause.
Whether the petitioner’s appointment, though in an acting capacity, effectively constituted a permanent appointment for purposes of security of tenure.
Whether the MSU President’s actions—converting the petitioner’s permanent appointment to an acting one and designating a replacement without proper Board approval—were consistent with the prevailing rules on personnel appointments under the MSU Code of Governance and constitutional principles.