G.R. No. L-30773 - Sta. Maria vs. Lopez

Petitioner Felixberto C. Sta. Maria was Dean of the College of Education, University of the Philippines (UP), with a five-year term appointment effective May 16, 1967, until May 17, 1972.
Respondents were Salvador P. Lopez, UP President; the Board of Regents of UP; and Nemesio Ceralde, appointed acting Dean of the College of Education.

Since February 11, 1969, UP College of Education students (graduate and undergraduate) presented demands relating to academic program improvements, physical facilities, and other special issues.
President Lopez created a committee comprising students and faculty to negotiate with Dean Sta. Maria, which held nine meetings between February and March 1969.
Dean Sta. Maria submitted a written report to President Lopez outlining steps taken, being taken, and planned concerning student demands; he also recommended enhancements in budget, library, faculty appointments, facilities, and dormitory construction.
Despite partial concessions, students remained dissatisfied, particularly on abolition of foreign language requirements and clearer standards on academic and faculty matters.
A student boycott began on July 17, 1969, supported by the UP Student Council, culminating in a university-wide shutdown on July 23, 1969.

On July 23, 1969, President Lopez issued Administrative Order 77 transferring Sta. Maria from Dean of the College of Education to Special Assistant to the President with the rank of dean, without reduction of salary, citing “interest of the service” and urgency due to academic disruption.
Simultaneously, Professor Nemesio Ceralde was appointed acting Dean of the College of Education.
Sta. Maria protested, requesting formal investigation and reconsideration, and asserted the transfer was unjust and null.
The Board of Regents confirmed the transfer but allowed Sta. Maria the opportunity to be heard; he refused to recognize their jurisdiction unless the transfer was revoked.
Sta. Maria then filed a petition for certiorari, prohibition, and mandamus in the Supreme Court to challenge his transfer and seek restoration to his deanship.

Sta. Maria’s contract specified a five-year term “unless sooner terminated” with rights in accordance with University rules, the Constitution, and laws of the Philippines.
University rules and the UP Charter mandate fixed terms for deans, with no power for removal at will without cause and due process.
The position of college dean is a non-competitive or unclassified civil service post, enjoying constitutional protection against removal except for cause, with prior notice and hearing.

Respondents maintained that the transfer was not removal or punitive but a non-disciplinary, administrative reassignment in the interest of public service to resolve the crisis.
They further claimed the transfer was a promotion or enhancement since petitioner would assume broader responsibilities and higher rank within university governance.
They emphasized the principle of “least sacrifice” to end the academic disruption, offering either to retain Sta. Maria risking paralysis, or to suspend and investigate, or to transfer non-disciplinarily to defuse crisis.

Faculty members mostly expressed support for Sta. Maria’s retention and decried the summary transfer without due process.
Multiple declarations of concern from various faculties protested violation of rule of law and fundamental rights.
The editorial and independent voices called for reasoned and just administrative action rather than yielding to pressure from student protests.

Whether the transfer of Sta. Maria from Dean of the College of Education to Special Assistant to the President, without a reduction in rank and salary but without his consent, constituted a removal from office.
Whether the transfer was valid under the University rules, the Civil Service Law, and the constitutional right to security of tenure and due process.
Whether the President and Board of Regents had authority to effect such transfer without prior charges, hearing, and compliance with procedural due process requirements.
Whether the circumstances of student protests and academic disruption justified summary transfer or removal without due process.
Whether the petition for certiorari, prohibition, and mandamus was the proper remedy considering available administrative remedies.