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Case Study MGT

The Supreme Court ruled in favor of the Department of Education regarding the reassignment of Marilyn R. Yangson, clarifying that reassignment differs from transfer and is permissible under administrative discretion for public service needs. Yangson's claim of violation of her security of tenure was dismissed, as the Court upheld that reassignment does not equate to constructive dismissal. The decision emphasized the importance of clear communication and adherence to due process in personnel movements.

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48 views4 pages

Case Study MGT

The Supreme Court ruled in favor of the Department of Education regarding the reassignment of Marilyn R. Yangson, clarifying that reassignment differs from transfer and is permissible under administrative discretion for public service needs. Yangson's claim of violation of her security of tenure was dismissed, as the Court upheld that reassignment does not equate to constructive dismissal. The decision emphasized the importance of clear communication and adherence to due process in personnel movements.

Uploaded by

JONLOU DALIDA
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Colegio de la Purisima Concepcion

The School of the Archdiocese of Capiz


Roxas City 5800, Philippines
SCHOOL OF GRADUATE STUDIES

DPE 302: Leadership Behavior Organizational Climate and


Professional Development

IREEN M. DIONIO
DR. ELNORA A. BARRIOS
PhD Student
Professor

MARILYN R. YANGSON, PETITIONER, VS. DEPARTMENT OF EDUCATION


REPRESENTED BY ITS SECRETARY BRO. ARMIN A. LUISTRO, FSC,
RESPONDENT.
LEONEN, J.:
Reassignments differ from transfers, and public employees with appointments
that are not station-specific may be reassigned to another station in the
exigency of public service.

This resolves a Petition for Review on Certiorari [1] assailing the July 28, 2011
Decision[2] and January 4, 2012 Resolution[3] of the Court of Appeals in CA-G.R.
SP No. 117679.

I. Executive Summary
Marilyn R. Yangson, a Principal III at Surigao Norte National High School,
challenged her reassignment to another school ordered by the Department of
Education (DepEd). She argued the move violated her right to security of
tenure. The case went through the Regional Trial Court (RTC), the Court of
Appeals (CA), and eventually the Supreme Court (SC). The Supreme Court
ruled in favor of Department of Education, clarifying the distinction between
reassignment and transfer, and upholding the validity of administrative
discretion in personnel movements.

II. Background Information


Context: Marilyn R. Yangson was Principal III at Surigao Norte National
High School under the Department of Education.

Timeline: On April 30, 2008, Yangson was personally served a


Memorandum dated April 14, 2008 issued by then Assistant Schools
Division Superintendent Officer-in-Charge Fidela Rosas (Rosas). [5] In the
Memorandum, Yangson was reassigned from Surigao National to Toledo
S. Pantilo Memorial National High School (Toledo Memorial) effective
May 5, 2008.
Parties Involved:
Petitioner: Marilyn R. Yangson
Respondent: Department of Education, represented by Assistant
Schools Division Superintendent Fidela Rosas.
III. Case Details
Marilyn R. Yangson received a memorandum dated April 14, 2008,
reassigning her to another school. The reassignment was cited as necessary
for the "exigency of service." Marilyn R. Yangson questioned the
reassignment, arguing it was arbitrary and without her consent. She refused
to acknowledge the memorandum until consulting legal counsel. She filed a
petition for injunction to prevent her reassignment, claiming it infringed on
her right to security of tenure.

Actions Taken:
 Two (2) days prior to the effectivity of her reassignment on May 5,
2008, Yangson filed before the Regional Trial Court a Petition for
Injunction with Prayer for Temporary Restraining Order and Damages
against Rosas and Dulcesima Corvera (Corvera), who was supposed to
replace Yangson as the new principal of Surigao National. [8]
 Yangson alleged that the Memorandum violated Department of
Education Circular No. 02, series of 2005, because it failed to specify
the duration of her reassignment and because it was issued without her
prior consultation. She also claimed that there was no vacancy in the
position, and the reassignment would cause diminution in her rank. [9]
 On May 5, 2008, the Regional Trial Court issued a Temporary
Restraining Order.[10]
 The Department of Education appealed the RTC’s decision to the Court
of Appeals, which reversed the TRO and upheld the reassignment.
 Marilyn R. Yangson elevated the case to the Supreme Court.

IV. Issues and Problems


1. Did the reassignment of Marilyn R. Yangson violate her right to security
of tenure?
2. Was the reassignment made in accordance with administrative rules
and procedures?

V. Analysis

Legal and Administrative Context:


 Security of tenure protects employees from unjust dismissal but does
not guarantee a fixed station of assignment.
 Reassignment, as distinct from transfer, does not involve a change in
position or rank and is allowed under the law if made in the interest of
public service.
 DepEd cited service exigency as the reason for Yangson’s
reassignment, a legitimate ground under administrative rules.

Court's Reasoning:
 The Supreme Court held that Marilyn R. Yangson’s reassignment did
not constitute constructive dismissal.
 The Court clarified that reassignment is an administrative prerogative
and valid if conducted in the interest of public service.
 The memorandum was consistent with DepEd's authority to make
personnel changes for operational efficiency.

VI. Outcome or Resolution


The Supreme Court ruled in favor of the Department of Education. It
determined that the reassignment was was lawful and did not violate Marilyn
R. Yangson's rights. The decision clarified the distinction between
reassignment and transfer, emphasizing the DepEd’s prerogative to reassign
personnel for service needs.

VII. Lessons Learned


1. Reassignment as a Management Tool: Public sector organizations
have the authority to reassign personnel for operational efficiency,
provided it is not arbitrary or punitive.
2. Security of Tenure: Employees are protected from termination
without due cause but not from legitimate reassignments.
3. Clarity in Administrative Decisions: Clear communication and
adherence to due process are essential to avoid disputes over
personnel movements.

VIII. Recommendations
1. Department of Education should enhance transparency by providing
detailed justifications for personnel movements to mitigate perceptions
of arbitrariness.
2. Providing training on administrative law and personnel management
can reduce disputes and foster smoother transitions during
reassignments.
3. Introducing mechanisms for consulting affected employees before
reassignments may help address concerns and improve morale.

IX. References
1. Supreme Court Decision: G.R. No. 200170.
https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/65238?
form=MG0AV3
[1]
Rollo, pp. 9-31.
[2]
Id. at 32-44. The Decision was penned by Associate Justice Japar B.
Dimaampao, and concurred in by Presiding Justice Andres B. Reyes, Jr.
(now a member of this Court) and Associate Justice Jane Aurora C.
Lantion of the First Division, Court of Appeals, Manila.
[3]
Id. at 45-46. The Resolution was penned by Associate Justice Japar B.
Dimaampao, and concurred in by Presiding Justice Andres B. Reyes, Jr.
(now a member of this Court) and Associate Justice Jane Aurora C.
Lantion of the Former First Division, Court of Appeals, Manila.
[4]
Id. at 32.
[5]
Id. at 32-33.
[6]
Id. at 47.
[7]
Id. at 33.
[8]
Id.
[9]
Id. at 54.
[10]
Id. at 33 and 54-55.
2. Administrative Code of the Philippines.
3. DepEd personnel management guidelines.

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