Security of tenure protects career, non-career positions

We note that respondent Mayors claim that petitioner was occupying a primarily confidential position was not actually invoked in the second dismissal of 8 February 1988. In his Memorandum dated 8 February 1988 to respondent Treasurer, respondent Mayor merely reiterated the first summary dismissal as a ground for the second termination after he was reinstated on 20 March 1986. As we held in Cortez vs. Bartolome: As an employee in the civil service and as civil service eligible, respondent is entitled to the benefits, rights and privileges extended to those belonging to the service. He cannot be removed or dismissed without just cause xxx. Moreover, in the more recent case of Jocom vs. Regalado, we emphasized that the constitutional and statutory guarantee of security of tenure is extended to both those in the career and non-career positions. [G.R. No. 107841. November 14, 1996]