Case Summary (G.R. No. 119903)
Factual Background
Dr. Bienvenido A. Icasiano was appointed as Schools Division Superintendent for Quezon City by President Corazon C. Aquino in 1989. In 1994, Secretary Ricardo T. Gloria recommended that Dr. Icasiano be reassigned to the Marikina Institute of Science and Technology to fill a vacancy. This recommendation was approved by the President and communicated to Dr. Icasiano on October 14, 1994. Despite requesting reconsideration of this reassignment, the Secretary denied his request. Dr. Icasiano filed a petition for prohibition on October 19, 1994.
Court of Appeals Proceedings
The Court of Appeals initially denied Dr. Icasiano's request for a Temporary Restraining Order (TRO) on October 26, 1994, but later issued a TRO that restrained the petitioners from enforcing the reassignment on November 22, 1994. The appellate court subsequently set a hearing for a preliminary injunction and ultimately issued a decision on March 28, 1995, declaring the reassignment to violate Dr. Icasiano's right to security of tenure.
Legal Issues Raised
The main issue determined by the Court concerned whether the reassignment of Dr. Icasiano constituted a violation of his security of tenure. Petitioners argued that there was no breach, while Dr. Icasiano asserted that the reassignment was indefinite and arbitrary.
Court of Appeals Rationale
The Court of Appeals asserted that the reassignment lacked a fixed duration or objective purpose, which signified that it was indeed indefinite. The recommendation indicating Dr. Icasiano’s qualifications implied that the reassignment was not temporary, further indicating a violation of the constitutional protection of security of tenure.
Presidential Immunity Controversy
Petitioners contended that the decision questioned an act of the President and was thus subject to presidential immunity from suit. However, the Court clarified that the actions in question were those of the petitioners in carrying out the reassignment, not a direct challenge to a presidential act. Claims of grave abuse of discretion by administrative bodies warrant judicial review in instances where the actions taken infringe upon the rights provided under the Constitution.
Invocation of Relevant Jurisprudence
Petitioners cited the case of Bentain vs. Court of Appeals, which established that indefinite reassignment resulting in a reduction of
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Case Overview
- This case is a petition for review on certiorari under Rule 45 of the Rules of Court.
- Petitioners include Secretary Ricardo T. Gloria and Director Nilo L. Rosas of the Department of Education, Culture and Sports (DECS).
- The petition challenges the decision of the Court of Appeals in CA-G.R. SP No. 35505.
Factual Background
- Dr. Bienvenido A. Icasiano was appointed as Schools Division Superintendent of Quezon City on June 29, 1989, by President Corazon C. Aquino.
- On October 10, 1994, Secretary Gloria recommended Dr. Icasiano’s reassignment to the Marikina Institute of Science and Technology (MIST) due to the retirement of its previous Superintendent.
- The President approved this reassignment on October 12, 1994, and Director Rosas informed Dr. Icasiano of the reassignment effective October 17, 1994.
- Dr. Icasiano requested reconsideration of the reassignment from Secretary Gloria, which was denied.
- On October 19, 1994, Dr. Icasiano filed a petition against the reassignment.
Proceedings in the Court of Appeals
- The Court of Appeals denied Dr. Icasiano’s request for a Temporary Restraining Order (TRO) on October 26, 1994.
- On November 22, 1994, this resolution was set aside, and a TRO was issued, preventing the petitioners from impleme