Question Transfer from same agency

Hi good day,
I'm teacher for 7years (permanent) and currently applied for transfer.May document approved and requested to comply necessary requirements last August 7,2021 by division(new)with effective first day on September 13.The division(former) comply last August 25,2021 and submitted to regional office on the same date.However the region office forwarded only last September 16,2021 to other Regional office(new).Then, Region(new)forwarded last September 29,2022 to division office(new).Now,question is there really GAP in my service?And division of says that I'm only reemployed because there is GAP due to non comply to submit paper before designated date of my transfer.

Under the Omnibus Rules on Appointment and Other Human Resource Actions (ORAOHRA) (Revised 2018), specifically Section 11, Paragraph C, transfer has been defined, as follows:

Sec. 11. Nature of Appointment. The nature of appointment shall be, as follows:

x x x

c. Transfer – the movement of employee from one position to another which is of equivalent rank, level or salary without gap in the service involving the issuance of an appointment.

The transfer may be from one organization unit to another in the same department or agency or from one department or agency to another: Provided, however, that any movement from the non-career service to the career service and vice versa shall not be considered as a transfer but reappointment.

An employee who seeks transfer to another office shall notify the head of the department or agency in writing where he/she is employed at least thirty (30) days prior to the effective date of his/her transfer. The head of the department or agency shall notify the employee in writing of the approval of the request to transfer within 30 days from date of notice.

If the request to transfer of an employee is not granted by the head of the department or agency where he/she is employed, it shall be deemed approved after the lapse of 30 days from the date of notice without the need to notify the employee concerned.

It is understood that the employee who seeks to transfer is cleared from all money, property and work-related accountabilities.

If, for whatever reason, the employee fails to transfer on the specified date, he/she shall be deemed resigned. However, should the employee opt to remain in the same agency before the specified date of transfer, the employee may be reappointed if there is no gap in the service or reemployed if there is a gap in the service. In both cases, the employee shall undergo the usual hiring process.