One person's numbers
Liza was promoted to sales supervisor at an appliance distributor in Pampanga. Her package: ₱45,000 basic, plus sales commissions that averaged ₱8,000 a month in 2026.
Two questions came up at her first December as a supervisor. Is she still entitled? Yes — PD 851 covers rank-and-file employees, and “rank-and-file” there means anyone who isn't a managerial employee as defined by the Labor Code. Supervisors who don't lay down management policies or hire and fire are covered. And do the commissions count? Her company's payroll treats them as incentives on top of salary, so her 13th month is ₱45,000. If they were counted, it would be ₱53,000.
Commissions: the Supreme Court has gone both ways
In Philippine Duplicators v. NLRC (1993, affirmed in 1995), commissions that formed part of salespeople's regular pay for each sale were treated as part of basic salary for the 13th month. In Boie-Takeda Chemicals v. De la Serna (1993) productivity-type incentives were excluded. The deciding question is whether the commission is really pay for work done (part of the wage structure) or a bonus-like incentive.
Purely commission-paid employees (no fixed salary) are among those listed as not covered in the 1987 guidelines. If your pay is mostly commissions, read your contract and payroll history — and ask HR in writing how your 13th month is computed.