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De Rama v CA appointed without reference to any position hence she is

not entitles to stay permanenty at any specific school.


Finally, the Court finds that the reason for her
where Rama calls for the nullification of several reassignment was for her to showcase her expertise in
appointments made by former mayor Abeja the Court held other schools hence it cannot be said that her
that only the CSC has the power to recall appointments reasignment was done capriciously or arbitrarily.
based on legal grounds under the Revised Administrative
Code; Here the ground cited by Rama that the
appointments were considered as midnight appointments
was not among those listed under the law; further the
prohibition against midnight appointments is applicable
Gloria v Icasiano and CA
only to outgoing president and not to outgoing mayor;
Icasiano was appointed as School Divisions
Superintendent and was reassigned as Vocational
Superintendent of Marikina Institute of Science and

Nazareno v City of Dumaguete Technology allegedly in a temporary capacity; Icasciano


now claims that her transfer is violative of her security of
tenure; The Court ruled in favor of Icasciano that a
REMOLLO made several midnight appointments before reasiggnment that is indefinite and results in a reduction
Perdices won for mayorlty post; The Court held that in rank, status, and salary is in effect a constructive
although the Constituion does not prohibit midnight removal from service; here Icasiano's reassignment was
appointments by Mayors or local officials tthis does not not indefinite and without her consent such transfer is
preclude the application of the reason behind said invalid.
prohibition over the president; which is to discourage
losing candidates to issue appointments for mere
partisan purposes. Further here the Court held that mass
appointments can only be valid if they have undergone
regular screening process and there is proof that
Fernandez v Sto Tomas
appointee is qualified there is a need to fill up several
Where Fernandez and De Lima as Director assigned in the
vacant offices immediately and appointments are not in
Commission Head office or central office of the Office of
bulk; here all of these requisites were not present hence
the appointments are invalid. Personal and Inspection and Audit (OPIA) were, by virtue
of a resolution, transferred to the regional office they filed
a case before the court claiming that such transfer is
invalid; the Court however held that such transfer was

Sta Maria v Lopez valid because this did no involve a transfer to another
office but merely a reassignment from the central office to
regional offices and had been effected with express
Where Sta Maria Dean of the College of Education was authority;As a general rule: An employee may be re-
transferred to being a special assistant under the assigned from one organizational unit to another in the
President by virtue of requests from his students files same agency, Provided, That such re-assignment shall not
before the Court claiming that such transfer was invalid involve a reduction in rank status and salary. there was
absent his consent and is a violation of his right to no violation of their right to security of tenure for their
security of tenure. The Court held that such transfer was transfer was made without a change in their position as
a demotion and is in fact in violation of his right of Director IV and no dimunition of rank status or salary; in
security of tenure; as a special assistant he merely assists fact in the first place they did not have a vested right to
the president and does not make authoritative decisions serve only at the central office
in his own name and responsibility; further such position
of special assistant is created only by the university
president as opposed to his previous position as dean
which was conferred by the university charter.

DECS v CA and Navarro


Gloria Navarro was appointed as School Principal II
without reference to any school; she was assigned at
Carlos Albert High school and 10 years later she was
transferred to Manuel Roxas High School without
dimunition neither in rank nor in salary; She now
complains before the court claiming that her
reassignment was invalid without her Consent; However
the Court upheld the reassignment claiming that she was

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