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SECTION 13.

 Other Human Resource Actions. — The following


human resource actions which will not require the issuance of an
appointment shall nevertheless require an Office Order issued by the
appointing officer/authority:
a. Reassignment — movement of an employee across the
organizational structure within the same department or
agency, which does not involve a reduction in rank, status
or salary.
Reassignment shall be governed by the following:
1. Reassignment of employees with station-specific place of
work indicated in their respective appointments
within the geographical location of the agency shall
be allowed only for a maximum period of one (1)
year. The restoration or return to the original
post/assignment shall be automatic without the need
of any order of restoration/revocation of the order of
reassignment.
An appointment is considered station-specific when:
(a) the particular office or station where the position
is located is specifically indicated on the face of the
appointment paper; or (b) the position title already
specifies the station, such as Human Resource
Management Officer, Accountant, Budget Officer,
Assessor, Social Welfare and Development Officer,
and such other positions with organizational
unit/station-specific function. Such position titles are
considered station-specific even if the place of
assignment is not indicated on the face of the
appointment.
2. If an appointment is not station-specific, the one-year
maximum period of reassignment within the
geographical location of the agency shall not apply.
However, the employee concerned may request for a
recall of the reassignment citing his/her reasons why
he/she wants to go back to his/her original station.
The reassignment may also be revoked or recalled by
the appointing officer/authority or be declared not
valid by the Civil Service Commission or a competent
court, on appeal.
3. Reassignment is presumed to be regular and made in
the interest or exigency of public service1 unless
proven otherwise or if it constitutes constructive
dismissal. Constructive dismissal exists when an
official or employee quits his/her work because of the
agency head's unreasonable, humiliating, or
demeaning actuations, which render continued work
impossible because of geographic location, financial
dislocation and performance of other duties and
responsibilities inconsistent with those attached to
the position. Hence, the employee is deemed illegally
dismissed. This may occur although there is no
diminution or reduction in rank, status or salary of
the employee.  ETHIDa

Reassignment that constitutes constructive dismissal


may be any of the following:
i. Reassignment of an employee to perform
duties and responsibilities inconsistent
with the duties and responsibilities of
his/her position such as from a position of
dignity to a more servile or menial job;
ii. Reassignment to an office not in the existing
organizational structure;
iii. Reassignment to an existing office but the
employee is not given any definite set of
duties and responsibilities;
iv. Reassignment that will cause significant
financial dislocation or will cause
difficulty or hardship on the part of the
employee because of geographic location;
or
v. Reassignment that is done indiscriminately
or whimsically because the law is not
1
Situations wherein there will be disruption in the delivery of basic or vital services or emergency/crisis
situation or there is a need to respond to the demands of public service.
intended as a convenient shield for the
appointing/disciplining officer to harass or
oppress a subordinate on the pretext of
advancing and promoting public interest
such as reassignment of employees twice
within a year, or reassignment of career
service officials and employees with valid
appointments during change of
administration of elective and appointive
officials.
Reassignment that results in constructive dismissal
must be sufficiently established.
  (2017 Omnibus Rules on Appointments and Other Human Resource Actions,
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CSC Resolution No. 1701009, [June 16, 2017])

Taking off the foregoing premises, the reassignment must be to an office


within the organizational structure, i.e., OED, and that the reassignment
should provide a definite set of duties and responsibilities and not merely
be couched in general terms. Since she occupies a position that is
supervisory in nature, the reassignment should specify that she will be
given tasks or functions that are supervisory in nature also.

Moreover, the reassignment should be done in the interest or exigency of


public service and is reasonable, not indiscriminately or whimsically.

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