PNP MEMORANDUM CIRCULAR NOS.

2018-011 AND 2013-014: A POLICY PAPER

ANALYSIS

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 I.

INTRODUCTION

At present, there are innumerable policies and rules and regulations concerning to the placement
and promotion of Senior Police Commissioned Officers (PCOs) to third and second level positions
which caused perplexities among the Officers vis-à-vis their career advancement. With this, the
Directorate for Personnel and Management (DPRM) crafted a comprehensive policy entitled: Placement
and Promotion System for Police Commissioned Officers to Third-Level Positions, which aims to set
clear and complete guidelines on placement promotion of Senior PCOs. However, the resulting policy
may have comprehensive procedures but nevertheless the same is potentially a target of violations due to
its lack of penalty clause in the memorandum itself.

In connection with the above-mentioned and with the aim of pursuing strategies to assure
acquiescence of the Senior Police Commissioned Officers (PCOs) so as gauge to bare bones the
expediency of mechanism contained in the Memorandum Circular governing the placement and
promotion system, this policy analysis will flow directly with the rationale of having an inevitable
penalty clause that will unswervingly motivate compliance and respect to the governing procedures set
in the Memorandum Circular.

In harmony with the said intentions and in determination of eluding the system of meritocracy
lobbing in the PNP in terms of placement and promotion, this paper will ponder in emphasizing the
systematic character of giving importance to skills and competence of police officers rather than their
connections in the bureaucracy. As the central model for integrity and honor, the PNP as a government
organization shall develop measures to advance accountability, competence and integrity in the
bureaucracy. Equally, PNP officers shall act with the highest degree of professionalism, integrity and
courtesy in respect to career ladder system, to begin with.

Therefore, the end goal of this paper is to empower and strengthen the governing Memorandum
Circulars on promotion of Senior Police Commissioned Officers (PCOs) to third and second level
positions by securing compliance through imposition of penalties, composing of suspension and
payment of damages, against parties proven to have violated the rules and procedures.

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 II.

OBJECTIVES

This policy paper analysis aims to examine existing policies in terms of effectivity, efficiency
and stringent implementation. Its earnest intention is to digest each and every provisions of existing
policies instituting streamlined and more efficient system of processing requests for transfer of personnel
from one office or unit to another. Likewise, to validate these memorandum circulars in providing
proactive and service-oriented personnel services in the placement of uniformed officials. Likewise, this
analysis is designed mainly to verify if PNP offices and units are actively participating in the evaluation
of personnel joining and leaving their jurisdiction. Vis-à-vis to confirm prior coordination between the
losing and gaining unit on the request for reassignment, transfer or detail of personnel so as to attest PNP
office/units and personnel in assuming responsibility and accountability in the placement of personnel.

Auxiliary, this will further analyze the career ladder system and review the guidelines for the
placement of senior PCOs to third level positions and their promotion to third level ranks and to revisit
the policies and procedures in governing the placement of Second (2nd) level uniformed personnel. This
will examine the equal access and opportunity for professional growth and career advancement for all
eligible PCOs regardless of the source of commission, gender and affiliation, whether current policies
satisfy a rational, fair and transparent placement and promotion system using merit and fitness as the
primary considerations and as enshrined in our laws and policies.

Finally, to scrutinize whether existing policies corroborate actual implementation and

enforcement in harmony with each and every provisions. This analysis will likewise box out the
concrete situational cases and scenarios based on tangible observations directly attacking the proper
execution of the policies ergo to enjoin transgressions, if any, encroaching rules and regulations thereby
circumventing the spirit and rationale of the policies thereto.

Thusly, the end goal of this analysis is to revisit the existing policies and examine their
consistency with the implementation and enforcement, in promoting professionalism and fairness
through the institution of a promotion and placement system using merit and fitness as the primary
consideration. Hence, if the existing provisions of the policy appears to be competent but lacking in
proper implementation due to absence of imposable penalties in case of violation, then the latter shall
be crafted to compliment the policy.

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 III.

CRITERIA FOR ASSESSMENT

1. RELIABILITY AND VALIDITY

This criterion tests the measures whether the same is unambiguous, unconstitutional,
and/or against public policy, good morals and customs. The policies should be straightforward and
simple to measure. Their application shall not contravene any existing laws, rules and regulations.
Likewise, such policies shall not be inconsistent with the provisions to any ordinances.

2. ECONOMIC CRITERION
This criterion focuses on the impact on the economy particularly on expected public
sector revenues on government spending. This criterion will be employed on the marginal cost,
that is, the additional tasks of DPRM in governing the placement and promotion of the
commissioned officers to third-level positions. Moreover, this criterion will specifically
concentrate on the cost and benefit analysis.

3. TECHNICAL CRITERIA

This criterion gives emphasis on technical feasibility, specifically whether the procedural
technicalities of the policy is readily available for implementation and execution. This policy
analysis will focus on technical criteria which may question whether the measurement of criteria
can be conducted at the desired level of reliability and validity.

4. POLITICAL CRITERIA

Political focuses on viability asks whether or to what extent a proposed policy alternative
will be acceptable to relevant powerful groups, decision makers, legislators, administrators,
citizens, neighborhoods, unions, or others. Further, this will give emphasis on whether the
proposed alternative legal under current law, or will statutes have to be amended or enacted.

5. ADMINISTRATIVE CRITERIA

Since many public policies are implemented by public agencies. Therefore, administrative
operability or administrative ease are often used as criteria for judging proposed public policies.

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 III.

PROBLEM STATEMENT

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 1. The high probability of violations in the governing rules and procedure in the promotion and
placement of commissioned officers third-level positions since there is absence of provisions
containing penalties and suspensions in violation to such rules and procedures; and
2. The actual observation of violations with regards to the guidelines and gradual procedure in
placement of second level uniformed personnel, particularly the following;

a. Item (k) of page 4 of this Annex (B), wherein based on actual observation,
newly graduated PO1 are being reassigned to other units without completing the required five
(5) year of service in their respective units. The policy unequivocally provided that PNP
uniformed personnel originally recruited in SAF shall be eligible for transfer only after five (5)
years of duty with SAF, counting from his graduation from Special Action Force Commando
Course (SAFCC) or any equivalent foundation course;

b. Item (m) of page 5 of this Annex (B), wherein PO1s and PO2s were being
allowed to undergo occupational eligibility training despite of the Senior PNCOs who are
elective to be lined-up. The policy unambiguously dictates that Only PCOs with the rank of
PSINSP and higher and PNCOs with the rank of P03 and higher shall be allowed to undergo
any occupational eligibility training with the exception of occupational eligibility courses
exclusively offered to SAF, MG and AVSEGROUP personnel such as Airborne, EOD Course
among others;

c. Item (m) of page 5 of this Annex (B), wherein, based on the actual observation,
officers who are mostly detailed outside PNP are PO2 and PO1 without any proper training or
knowledge/skills and they are being promoted for the reason of being under quota; and

d. Finally, based on actual observation, reassignment of personnel is not being

processed properly because of the so called “palakasan system”. Procedures are provided in this
Memorandum Circular, particularly, page 8 of Annex B, wherein the gradual procedure for Personnel
Initiated Request is provided.

IV.

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 POLICIES TO BE EVALUATED

This paper will focus on the two existing policies namely:

1. PNP MEMORANDUM CIRCULAR NUMBER 2018-011

PLACEMENT AND PROMOTION SYSTEM FOR POLICE COMMISSIONED OFFICERS
TO THIRD-LEVEL POSITIONS; and
2. PNP MEMORANDUM CIRCULAR NUMBER 2013-014
PRESCRIBING THE POLICIES AND PROCEDURES GOVERNING THE PLACEMENT
OF SECOND(2ND) LEVEL UNIFORMED

The PNP Memorandum Circular Number 2018-011 on Placement and Promotion System for
Police Commissioned Officers to Third-Level Positions consolidates all policies, guidelines,
procedures, rules and regulations of the NAPOLCOM, the CSC, and the PNP governing the placement
and promotion of senior Police Commissioned Officers (PCOs) to third level positions in the PNP.
Since presently, there are various policies and rules and regulations pertaining to the placement and
promotion of senior police Commissioned Officers to third level positions in the PNP. Thus, many
senior PCOs are confused on what and when are these policies applicable to them. This Memorandum
Circular will provide equal opportunity and level the playing field for all senior PCOs who will be
designated to nay third level positions, provided they satisfy all the mandatory requirements.

Basically, the policy discusses on the guidelines and procedures in the placement of PSSUPT
Entry Positions wherein;

Placement to PSSUPT Entry Positions:

a) The SOPPB Secretariat shall continuously accept applications for placement of PSUPTs to PSSUPT
T.O. positions;

b) Each Office/Unit shall have their respective Officers Placement and Promotion Board (OPPB)
which shall deliberate the positions, designate qualified PCOs as OlCs, and endorse the applicants to
the concerned Directorates where the position/designation or functional specialization of the applicant
is categorized at the time of application for competency evaluation and placement interview;

c) Upon completion/passing the said evaluation and interview, the concerned Directorate will prepare
and endorse the applicant to DPRM (Attn: C, SOPPD/Head Secretariat, SOPPB). If in case the

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applicant fails the said evaluation/interview, DPRM will issue a memorandum directive to the
concerned Head of Office/Unit directing him/her to place the applicant under three (3) months’
probation to prove whether he/she is qualified to occupy said position. Upon completion of the said
probationary period, the Head of Office/Unit shall have the prerogative to re-endorse subject PCO for
competency evaluation and placement interview or designate a new PCO in his/her T.O. position being
occupied;

d.) If in case the applicant passes the said evaluation and interview of the concerned functional
Directorate, DPRM will in turn issue a memorandum directive to the concerned Office/Unit Head
informing him/her that the applicant has passed the evaluation/interview of the concerned Directorate
and direct the preparation/issuance of orders changing the designation of the applicant from Officer-In-
Charge to Acting capacity and that the applicant is now cleared to take the CADEx at the SOPPD
DPRM Office, Camp BGen Rafael T Crame, Quezon City;

Before the applicant is allowed to take the CADEx, he/she must first submit the following
documentary requirements to the Assessment Section, SOPPD, DPRM/SOPPB Secretariat for the
Secretariat to determine/grant a schedule for the applicant to take the CADEx:

e.1) Endorsement from the functional Directorate concerned which conducted the competency
evaluation/interview;

e.2) Authenticated copy of Office/Unit OPPB Resolution endorsed by the Office/Unit Head
designating the applicant in Acting Capacity;

e.3) Duly notarized and completely accomplished computerized SOPPB Application Form (It is the
duty and responsibility of the PSUPT applying for 3rd level placement and promotion to find means
and ensure that the entries in his/her application form are complete, updated, and synchronized with
his/her PNP DPRM PAIS PDS from the date the applicant took oath in the PNP service up to his/her
present designation at the time of application. If the applicant can no longer secure copies of his
required documents, he/she must secure a certification from his former offices/units attesting to his
records thereat); and

e.4) Latest 3R high definition colored whole body, white background photograph of the applicant in
PNP GOA "A" uniform, without headgear (refer to Oplan 'Tamang Bihis")

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g.) The applicant will be allowed to take the CADEx for a maximum of five (5) times only on his/her
scheduled day of examination to be determined by the SOPPB Secretariat. The passing rate of the
examination is 75%;

h) If in case the applicant fails to achieve the passing rate after taking the exam for five consecutive
times, he/she will be barred from retaking the exams for a minimum of one month to give ample time
for the candidate to review;

i) If in case the candidate still fails to pass the exams after being given a month to prepare, he/she will
again be barred from re-taking said exams for another month_ This cycle will continue until the
candidate achieves the passing rate of 75%;

j.) If in case an applicant who already passed the CADEx is relieved/redesignated to another T.O.
position belonging to a different functional Directorate before his/her application was endorsed by a
SOPPB En Banc resolution and approved by the CPNP, the applicant must again undergo the process
from the start as stated in paragraph 6 sub paragraph a.1 of this MC; and

k) The CADEx will only be available to all applicants from Mondays to Fridays from 8:00 AM to 4:00
PM.

Parenthetically, for the Promotion to PSSUPT was provided in the gradual manner below;

a) After passing the CADEx, SOPPB Committee "Alpha" will conduct promotional interview for
applicants who are holding administrative T.O. positions; and SOPPB Committee "Bravo" for those
who are occupying operational T.O. positions; b) After passing the interview and evaluation of SOPPB
Committee "Alpha/Bravo," the SOPPB En Banc will convene to either confirm or defer the promotion
of the said applicant. If the applicant is confirmed for promotion, SOPPB En Banc will pass a
resolution recommending the applicants promotion to PSSUPT prior submission and validation of
mandatory documents for promotion, and conduct of drug test and Neuro-Psychiatric examination,
subject to the approval of the Chief, PNP; c) With the approval of the Chief, PNP, the resolution,
including the clear book of original/duly authenticated pertinent documents for promotion will be
evaluated/validated by the Promotion Section, SOPPD, DPRM. After successful evaluation, the
promotional folders/documents will be forwarded to NAPOLCOM and the CSC for confirmation, and
eventually to the Office of the Executive Secretary prior approval of the President of the Republic of
the Philippines; and

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 d) Upon approval of the promotion, DPRM will issue promotion orders and a memorandum directing
the concerned office to issue orders designating the newly promoted PCO to full time capacity in
his/her

Finally, the placement and Promotion of Third Level Officers was provided in the Memorandum
Circular as follows:

a) After publication of the vacant positions for PDDG, PDIR, and/or PCSUPT, the SOPPB Secretariat
will start screening the applicants/recommended senior PCOs for placement to entry positions which
require promotion;

b) Pre-assessment shall be conducted by the SOPPB Secretariat through the Assessment Section,
SOPPD, DPRM to identify related previous assignments, SLL ranking, significant accomplishments,
and functional specialization; and to determine the minimum QS and pending criminal/administrative
case(s). The SOPPB Secretariat will also request for clearance/background investigation from DLOD,
DPRM/PNP IAS/DI/DIDM/other related investigative/intelligence.

gathering agencies as may be required by the members of the SOPPB;

c) The SOPPB En Banc will conduct the final deliberation on the recommendation of the SOPPB
"Alpha" (administrative positions) and SOPPB "Bravo" (operational positions) before passing a
resolution recommending the designation of the candidates;

d) The SOPPB Executive Committee shall vet, select and recommend to the Chief, PNP, candidates for
placement and promotion to the PNP Command Group, Directors of D-Staff, Regional Directors, and
Directors NSUs;

e) The role of the SOPPB is recommendatory in nature. The Chief, PNP shall be the approving authority
of all resolutions deliberated by the SOPPB. Placement requiring promotion shall be processed in
accordance with established procedures for promotion of third level officers; and

f) Upon approval, DPRM will issue appropriate orders.

Placement of 3rdLevel PCOs to PDs/CDs/COPs in NCRPO positions:

a) After publication of the vacant positions for PDs/CDs/COPs in NCRPO, the SOPPB Secretariat will
start accepting the application for initial assessment;

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 b) The pre-assessment shall be conducted to identify previous assignments, SLL, significant
accomplishments, and pending criminal administrative case(s);

c) The SOPPB "Bravo" will evaluate, vet and select qualified candidates during deliberation and
recommend candidates to the SOPPB en banc before passing a resolution recommending the list of
eligible PCOs (three candidates for PD positions and five candidates for CD/COP, NCRPO positions)
for approval of the Chief, PNP;

d) The Chief, PNP is the sole and final authority in the placement of third level officers and shall be the
approving authority of all resolutions deliberated by the SOPPB. The NAPOLCOM shall be given a
copy of the resolutions for its information (NAPOLCOM MC No. 2017-001);

e) Upon approval of the Chief, PNP, the Placement Section, SOPPD, DPRM will prepare the necessary
documents and endorse the list of eligible PCOs to the concerned Regional Directors for subsequent
transmittal to the concerned LCEs for them to choose their respective PD/CD/COP, NCRPO; and

f) After selection by the concerned LCEs, the concerned Office/Unit Heads will endorse the name of the
chosen PD/CD/COP, NCRPO to DPRM (Attn: C, SOPPD/Head Secretariat, SOPPB). Upon receipt of
the endorsement, DPRM will issue appropriate orders to be implemented by the concerned Office/Unit
Heads.

The general guidelines as provided in the Memorandum Circular, all candidates for placement
and promotion to third level positions must possess the necessary qualification standards of the rank
required for the position prior to final interview, as follows; 1.) Education; 2.) Master's Degree; 3.)
Bachelor of Laws (LLB) with certificate of bar eligibility from the Supreme Court (CHED Resolution
No.038-2001 re Equivalent of a Master’s Degree); 4.) Doctor of Medicine (MD) with certificate of
eligibility from Professional Regulations Commission (CHED Resolution No. 038-2001 re Equivalent of
a Master’s Degree); or 5.) Allied Master's Degree.

As to training requirement, an applicant must have completed: 1) Public Safety Officers Senior
Executive Course (PSOSEC); 2) General Staff Course (GSC) as accredited by the Directorate for
Human Resource and Doctrine Development; 3) Experience/TIG, in which the minimum requirements
are: 3.1) TIG for 3rd level PCOs; 3.2) Promotion from Police Superintendent to Police Senior
Superintendent - four continuous years from the date of last promotion; and 3.3) Promotion from Police
Senior Superintendent to Police Chief Superintendent - three continuous years from the date of last

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promotion. Lastly, 4.) Promotion from Police Chief Superintendent to Police Director, PDDG, and PDG
- PCSUPT experience (CSC Res. No. 1401222 dated August 18, 2014), no time in grade required.

As to eligibility, the applicant must be eligible for 1) Police Executive Service (PESE); 2) Career
Service Executive (CSEE); 3) Career Executive Service (CESE); 4) Career Executive Officer (CEOE)
taken prior to 2010 (CSC Res. No. 1401222 dated August 18, 2014); 5) Police Officer 1st Class (PO 1st
Class) acquired prior to CY 2003 (CSC Res. No. 1401222 dated August 18, 2014); or 6) Police
Superintendent (PSUPT) acquired prior to CY 2006.

The PNP promotion system should be based on merits and on the availability of vacant positions
in the PNP Staffing Pattern and shall be gender fair to ensure that women members shall enjoy equal
opportunity for promotion as that of men; 3) All promotions to the ranks of PSSUPT up to PDDG shall
be for reason of vacancy both in position and rank. No officer shall be promoted to any third level rank
unless he is holding a position requiring such rank. In case there are no PCOs with the rank required for
the position, it shall be given to the most qualified next lower rank PCO who must be eligible for
promotion. The primary determinant shall be the candidate's qualification, capability, and competence to
perform the assigned task and not merely seniority; 4) A PCO who has applied for promotion shall not
be relieved from his present position until he/she has been promoted, unless relieved for cause.
Otherwise, the PCO shall no longer be eligible for promotion as the PCO no longer holds a position
commensurate to the rank applied for. In addition, a PCO who has just been promoted shall not be
qualified to apply and/or occupy another position for at least three (3) months after the effectivity date of
promotion; 5) The established PNP Career Ladder System shall be strictly observed except in cases
where exigency of the service so requires otherwise; 6) The PNP Career Ladder System also specifies
the Time-In-Position (TIP) required for each position. The TIP shall be strictly observed and no third
level PCO shall be qualified to apply from one key position to another higher key position if the PCO
has not met the minimum TIP.

Meanwhile as provided in PNP Circular No. 2009-019 dated October 30, 2009 entitled
"Guidelines and Procedures in the Grant of Special Promotion of Uniformed Personnel of the PNP, there
shall be no special promotion from PSUPT to Third level ranks. There shall also be a considerable
balance between competencies and seniority. Candidates for placement must neither be too junior nor
too senior for a particular position. While the PNP culture considers seniority as an important criterion in

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the selection and placement of officers, the qualifications and competencies of candidates shall be taken
into account with at least equal, if not, more importance.

On the other hand, PCOs who were promoted ahead of their peers through special promotion
shall be treated as part of the immediate class preceding his year of commissionship in the seniority
range. Thus, even if the officer was commissioned in 1996 and he was meritoriously promoted, his
current seniority range will be equivalent to that of 1995, then, he/she shall be treated as batch 1995.
Multiple special unmeritorious promotions shall be treated as one/single promotion only for this
purpose. Except for the CPNP, no PNP member who has less than one (1) year of service before
reaching the compulsory retirement age shall be promoted to a higher rank or designated to any other
position that calls for a higher rank.

Further, each Directorate shall formulate the parameters for their respective Core Competency
Lists which shall become a requirement for 3rd level positions under their respective functional fields.
The core competency lists shall be used as basis in designating PCOs to specific key positions requiring
specializations. Furthermore, assigning personnel in the 15 Directorates shall also be used as basis in
rating candidates applying for specific key positions.

The following are the functional fields of specialization in the PNP (including all units and NSUs
under their respective functional groupings: a) DPRM - personnel administration and human resource
management; qualified officers shall be conferred Human Resource Management Competency; b)
DHRDD - training and education; qualified officers shall be conferred Human Resource Development
Competency; c) DIDM - criminal investigation and detective management; qualified officers shall be
conferred Investigation and Detective Management Competency; d) DI - intelligence operations and
strategic management; qualified officers shall be conferred Intelligence Management Competency; e)
DO - operations management; qualified officers shall be conferred Operations Management
Competency; f) DPL - strategic planning and program management; qualified officers shall be conferred
Strategic Planning Management Competency; g) DPCR - police, community and media relations;
qualified officers shall be conferred Strategic Communications Management Competency; h) DC - fiscal
management and comptrollership; qualified officers shall be conferred Comptrollership Executive
Competency; i) DL - logistics and supply chain management; qualified officers shall be conferred
Logistics Management Competency; D DRD - research and development management; qualified
officers shall be conferred Research and Development Management Competency; and k) DICTM -

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information and communications technology management qualified officers shall be conferred
Information and Communications Technology Management Competency.

Similarly, DPRM shall cause the publication or announcement of vacant and likewise the
anticipated vacancy positions as well as the list of eligible PCOs to those positions before the SOPPB
conducts its deliberations. No PCO shall be included in the List of Eligibles for a particular position
unless he/she possesses all the mandatory requirements for that position. Equally, any officer who is not
included in the said list may not be designated to any of the third level positions in the PNP.

Ultimately, placement and promotion to third level positions shall at all times be based on merit
and fitness. The candidates must possess the qualification standards for the rank/position. The candidates
shall be further evaluated on their demonstrated abilities, talents, and competencies through close
scrutiny of his/her service/track record. There shall be a sound career management and planning for third
level officers. The pool of candidates shall not only include possible replacements to a vacant or soon-
to-be vacated position but also the next-in-line potential candidates to enable them to make plans,
programs and necessary preparations. It is necessary, that the potential candidates for the position are
prepared to handle the responsibilities and gained the needed managerial exposure required by the
aspired position.

However, in case of vacancy and lack of qualified 3rd level technical service officers, the Chief,
PNP may temporarily designate a qualified line service officer to occupy third level technical service
key command 17 positions until such time that a qualified third level technical service officer is
permanently appointed/designated pursuant to Section 26 of RA No. 6975.

Additionally, 3rd Level PCOs holding other positions of responsibility by virtue of their
specialization, technical expertise, and extended assignments in special fields or administrative units
may hold such position for a maximum period of two (2) years. They may then be designated to other
positions, if qualified. PCOs that have less than a year in the service may be allowed to hold their
current positions until retirement.

Except for the Chief, PNP, all PCOs occupying key/command positions, particularly PDs, CDs,
COPs (NCRPO), Regional Chiefs of NSUs and other similar key/command positions, whose tenure in
said key position is approaching the maximum two (2) years TOD and who are at the same time
approaching the one year reglementary period prior to his/her compulsory retirement age, may apply for

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reassignment to other key positions before either of said periods/circumstance takes place. Otherwise,
said PCOs may be relieved from their positions and will be reassigned to other positions as may be
determined by the SOPPB and/or upon recommendation of their respective Heads of Office/Unit.

Also as provided in the SOPPB Resolution No. 2013-093, A PCO who held a PD/CD/COP of
NCRPO position for a period of less than two (2) years shall not be designated to another key command
line position immediately after his relief, whatever is the nature of the relief. Instead, subject PCO must
occupy a staff position for a minimum period of six (6) months. However, the SOPPB may recommend
to the Chief, PNP the designation of the PCO to another PD/CD/COP of NCRPO position without
passing through a staff position if the situation so requires and in the exigency of the service. All officers
shall be given equal opportunity to be designated to any 3rd level position provided they satisfy the
minimum mandatory requirements. Previous positions held by candidates shall be considered in the
selection process in order to give those who have held hardship posts the chance to occupy better
positions. In no case shall any officer be assigned as Director of a Class "A" city, province or region to
another or from one so-called choice position to another. Nonetheless, Criss-crossing/changing career
paths in the career ladder framework for PNP officers may be allowed in circumstances where there are
no other qualified third level PCOs within a PRO, NSU, or Directorates in the NHQ to occupy the
vacant higher key positions available.

The Chief, PNP has broad command and direction powers under RA No. 6975. Included therein
is the power to designate a subordinate officer as PD/CD/COP in an acting capacity. Such designation is
not a pre-emption on the conferment powers by NAPOLCOM because by the nature of an "acting
capacity," it is essentially temporary and revocable in character and the holder of such appointment may
be removed anytime even without hearing or cause.

For purposes of increasing the objectivity in the selection process and evaluating the 3rd level
PCOs who are candidates for placement to key positions and other positions of responsibility, a rating
system with the following criteria shall be considered by the PNP SOPPB as a guide. The passing rate is
75%.

a) Pre-assessment Documentary Phase:

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a.1) Seniority (10 pts) - The relative seniority of an officer shall be based on the Seniority Lineal List
(SLL) and not by his or her Source of Commissionship (PMA/PNPA/LE) Class and/or date of
commission or retirement date;

a.2) Diversity of Assignment (25 pts) - 3rd level positions call for officers with vast experience in terms
of nature of responsibility as well as geographical assignment that influence their understanding of
different situations, cultures, beliefs, customs and traditions as they impact on policing. For purposes of
this MC, personnel assigned to national operational units like the PNP SAF, Regional Offices of NSUs
and mobile training teams may be considered as having served in the different regions or provinces
where their units were actually deployed; and

a.3) Awards and Recognition (Present Rank) (10 pts) - This criterion will assess the level of
excellence in the performance of duty by an officer as evidenced by awards received.

b) Interview and Evaluation Phase:

b.1) Competence to Assume Position and Leadership Experience (25 pts) - The competence of an
officer to assume 3rd level positions shall be determined by his/her strategic planning and decision-
making abilities when faced with difficult situations. Likewise, this is where his/her leadership skills and
experience come into major play; and

b.2) Service Reputation (30 pts) - The candidate shall be evaluated based on available information
pertaining to his/her personal and professional character. This shall include administrative/criminal cases
and derogatory records as well as feedbacks from his/her former superiors, peers, and subordinates.

For complaints and grievances, the PNP SOPPB shall entertain complaints and grievances
related to the implementation of the placement and promotion system within fifteen (15) days from the
publication of the order of placement and/or promotion. Complaints and grievances shall be submitted in
writing and must be under oath. The Board shall resolve such complaints within fifteen (15) days from
receipt thereof.

II.
PNP MEMORANDUM CIRCULAR 2013-014 T

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 THE POLICIES AND PROCEDURES GOVERNING THE PLACEMENT OF SECOND
LEVEL UNIFORMED PERSONNEL

This PNP Memorandum Circular (PNPMC) sets forth the policies and guidelines to
streamline the processes and procedures governing the reassignment, transfer or detail of second
(2nd) Level uniformed personnel from one office/unit to another. This PNPMC will also address
some of the policies on the placement of PNP personnel that are not anymore relevant to the current
situation.

Consistent with the PNP P.A.T.R.O.L. Plan 2030 and the PNP Strategic Focus
CODE-P: 2013 and beyond, the PNP is presently pursuing strategies to streamline and simplify the
processes and procedures in the reassignment, transfer or detail of personnel from one office/unit to
another. The purpose of this initiative is to provide costumer-oriented and efficient personnel
support services to PNP field units and personnel.

As provided in the said Memorandum and in harmony with the existing policies,
rules and regulations, the following policies shall be strictly observed in the placement of Second
(2nd) Level PNP uniformed personnel:

a. It is the policy of the PNP to maximize deployment of uniformed personnel

to the Field Units;

b. The maximum accumulated stay of PCOs in one Police Provincial Office

(PPOs) and District Office of NCRPO shall not exceed ten (10) years. They
shall be rotated within the territorial units of PROs in order to provide them
varied opportunities for career advancement and exposure to other field
duties to improve their leadership skills and capabilities.

c. Uniformed personnel (except those from Technical NSU) assigned at the

Headquarters who are performing menial and clerical duties/jobs shall be
downloaded to the Field Units;

d. Transfer of personnel shall only be allowed if there are available vacancies,

in position and in rank, at the gaining unit based on the existing 1997 DPL-
Approved Staffing Pattern. The implementation of any proposed position and
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 reorganization plan may be effected only upon approval of the DPL and
subject to the new Approved Staffing Pattern for the PNP;

e. Only PCOs with the rank of PCINSP and higher, and PNCOs with the rank of
SPOI and higher are allowed to be assigned at the Headquarters with the
exception of those who are assigned with the Technical Service Units;

f. PINSP, PSINSP POI, P02 and "03 shall be assigned to the PNP Field Units
only except on the following:

1) PCOs with the rank of PSINSP/PCINSP and PNCOs with the rank of at
least P03 can be assigned to PSPG as protective security detail;

2) PCOs with the rank of PSINSP and with at least four (4) years of field
duty can be assigned as Aide-de-Camp to Star Rank Officers designated
to Command Positions (PNP Command Group, RDs and NSU Directors);

3) PINSPs who were promoted from SP04 may not be required to be

assigned in the Field Units;

4) PNCOs with the rank of at least P02 who have rendered at least four (4)
years field duty can be assigned as driver/security to Senior Officers; and

5) PNCOs with the rank of at least P03 can be assigned to the Escort and
Honor Guard Battalion of HSS.

g. PCOs recruited to the PNP as pilots are considered technical officers and shall
only be assigned to the Air Unit of SAF. They are prohibited from transferring
to other units of SAF and any other offices/units of the PNP;

h. ITMS, CLG, ES, CES and HS personnel shall not be assigned to any other
unit;

i. PNP personnel who joined IAS shall no longer be assigned to other

PNP units based on the provisions of Section 45, R.A. No. 8551 and DILG
Circular 2009-13; this is an exception to para 7f of this PNPMC;

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 j. PNP personnel joining the IAS shall have at least a rank of PCINSP for PCOs
and SPOI for PNCOs per DBM Ref. No. 2001-C03136R;

k. PNP uniformed personnel originally recruited in SAF shall be eligible for

transfer only after five (5) years of duty with SAF, counting from his
graduation from Special Action Force Commando Course (SAFCC) or any
equivalent foundation course;

The NSUs are highly specialized units and assignment to these units is
considered higher level of policing, which requires a specialized skill. The
PNP personnel joining the NSUs (except IT units) shall have a rank of at
least PCINSP for PCOs and SPOI for PNCOs. They shall also have the
necessary occupational eligibility requirement prior to joining such
specialized units;
m. Only PCOs with the rank of PSINSP and higher and PNCOs with the rank of
P03 and higher shall be allowed to undergo any occupational eligibility
training with the exception of occupational eligibility courses exclusively
offered to SAF, MG and AVSEGROUP personnel such as Airborne, EOD
Course among others;

n. All PNP personnel undergoing mandatory and occupational eligibility

training shall be assigned to PHAU or RPHAU, as the case maybe. They will
be further detailed to the appropriate training institutions during the duration
of the training. Only DPRM and ARMD/RPHRDD are authorized to issue
training orders for purposes of accounting;

o. PNP personnel graduating from Occupational Eligibility Training shall be

assigned back to their former units;

p. All PNP uniformed personnel (except PSUPT) who undergo Mandatory

Career Courseñraining shall be reassigned back to their former unit;

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 q. PNP uniformed personnel who are newly promoted or has filed an
application for promotion shall not be eligible for transfer within six (6)
months from the date of the effectivity of such promotion;

r. Only PCOs with the rank of at least PSINSP and PNCOs with the rank of at
least P03 shall be deployed with the United Nations (UN) Peace Keeping
Mission;

s. Assignment of PNP uniformed personnel returning from the United Nations

(UN) Peacekeeping Mission shall be determined by DPRM based on
available vacancies at the gaining unit;

t. Only PCOs with the rank of PCINSP and higher and PNCOs with the rank of
P03 and higher, shall be allowed to be detailed outside of the PNP. The
provisions of NAPOLCOM Resolution No. 2010-145 shall be strictly
observed; this is an exception to para 7f of this PNPMC;

u. The detail of PNP uniformed personnel outside the PNP shall be approved by
the CPNP while detail of personnel within the PNP shall be approved by
TDPRM;

v. Swapping of personnel may be allowed among units, provided that no

provisions of this PNPMC will be violated. The applicant shall submit an
affidavit of swapping, together with the application form to the Admin Office
to facilitate this transfer arrangement;

w. Technical Officers assigned to Technical Units shall not be allowed to

transfer to line and other technical units. They may be detailed only to
provide technical expertise not available in the requesting offices/units
implementing a project but only for a fixed duration as determined in the
project document or for a period of six (6) months renewable every six (6)
months but shall not exceed two (2) years. However, technical service PCOs
of ITMS and CES assigned with the Anti Cyber Crime Group (ACC) may be
allowed detail, for purposes of continuity of their assigned jobs/tasks;

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 x. The Director of the technical service unit is the approving authority for the
detail of personnel to other units and the concerned technical unit shall
process and issue the corresponding detail order copy furnished DPRM;
y. Line Officers shall not be assigned to any technical offices/units of the PNP;

z. PNP personnel who were reassigned to other units shall only be eligible for
another transfer of unit after six (6) months from the effectivity of the last
transfer;

aa. Requests for amendment of detail, transfer or reassignment orders are not
allowed except when the issuance thereof is a violation of the policy;

bb. The transfer/reassignment of personnel is not one of the disciplinary

remedies. Directors and Chiefs of offices/units shall not request the transfer
of any personnel outside of his jurisdiction for disciplinary reason. They are
enjoined to exercise their disciplinary authorities and strictly impose order
and discipline in their respective powers. They shall not pass on to other
Directors, the burden of disciplining their subordinates;

cc. The practice of senior officers of bringing along with them an entourage of
personnel when they transfer from one office to another is not allowed.
However, they are allowed to bring with them to their new unit assignment
one (1) driver and one (1) security personnel;

dd. All PNP uniformed personnel shall seek self-improvement through career
development. They shall not directly or indirectly solicit influence or
recommendation from politicians, high ranking government officials,
prominent citizens and any persons affiliated with civil or religious
organization with regard to their assignment, transfer or promotion. The
provisions of R.A. 6713, otherwise known as Ethical Standard for Public
Officials and Employees," Art Ill, Section 2, Para 2.7, Section 3 and 7 of PNP
Code of Professional Conduct and Ethical Standards and Section 9 of
NAPOLCOM MC No. 93-013 must be strictly observed; and

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 ee. In the exigency of the service, the PNP can transfer, reassign or detail any
personnel to any unit as maybe necessary to effectively carry out the
functions/powers and duties of the PNP.

V.

ANALYSIS OF THE ALTERNATIVE ACTIONS

SWOT ANALYSIS PNP MEMORANDUM PNP MEMORANDUM

CIRCULAR 2018-011 CIRCULAR 2013-014
(Annex A) (Annex B)
STRENGTH The strong point of this The proficiency and
Memorandum Circular competency of improving
circulates on dodging the delivery of services to
confusion roughly on the the PNP field units and
placement and promotion of personnel through the
Senior Police Commissioned institution of a streamlined
Officers(PCOs) to third level and efficient processing of
positions in PNP. requests for reassignment,
transfer or detail of PNP
second (2nd) level uniformed
personnel.

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 WEAKNESS The assurance of rigid The actual observation of
implementation and unscrupulous violation
assurance of total circumventing the
independence from implementation of the
politically-inclined provisions on the following;
promotion and placement or e. Item (k) of page 4 of
from the system of this Annex (B), wherein
meritocracy. based on actual
- Lac observation, newly
k of rigorous provisions graduated PO1 are
which stretches criminal being reassigned to
liability, independent of other units without
administrative liability, if completing the required
violated. five (5) year of service
- Penalties, in their respective units.
suspensions and The policy
dismissal shall go unequivocally provided
together when that PNP uniformed
evidence would personnel originally
warrant. recruited in SAF shall
be eligible for transfer
only after five (5) years
of duty with SAF,
counting from his
graduation from Special
Action Force
Commando Course
(SAFCC) or any
equivalent foundation
course;
f. Item (m) of page 5 of

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 this Annex (B),
wherein PO1s and
PO2s were being
allowed to undergo
occupational eligibility
training despite of the
Senior PNCOs who
are elective to be
lined-up. The policy
unambiguously
dictates that Only
PCOs with the rank of
PSINSP and higher
and PNCOs with the
rank of P03 and higher
shall be allowed to
undergo any
occupational eligibility
training with the
exception of
occupational eligibility
courses exclusively
offered to SAF, MG
and AVSEGROUP
personnel such as
Airborne, EOD Course
among others;
g. Item (m) of page 5
of this Annex (B),
wherein, based on the
actual observation,

24 | P a g e
 officers who are
mostly detailed outside
PNP are PO2 and PO1
without any proper
training or
knowledge/skills and
they are being
promoted for the
reason of being under
quota;
h. Finally, based on
actual observation,
reassignment of
personnel is not
being processed
properly because of
the so called
“palakasan system”.
Procedures are
provided in this
Memorandum
Circular, particularly,
page 8 of Annex B,
wherein the gradual
procedure for
Personnel Initiated
Request is provided.
OPPORTUNITIES The policy serves as a The policy functioned
clearing and verification as a venue of corruption,
system to avoid confusion in unlawful activities and
the numerous policies. graft. This Memorandum

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 Uniform opportunities Circular is immune for
will cater the PNP officials corrupt act and practices
in case of placement and both with the applicant and
promotion. the designated approving
Parenthetically, body.
corruption may not be
inevitable thru an organized
procedure.
THREAT This policy sends a This policy drives the
threat for prospective PNP organization to a more
violations if stern and tainted image of unlawful
inflexible penalties would and illicit engagements.
not be visible in the said Moreover, this policy
policy itself. serves as a mere model of
ideal provisions of rules and
regulations without teeth
that bites when violated.

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 VI.

COMPARISON OF THE ALTERNATIVES

PNP MEMORANDUM CIRCULAR 2018-011 shall lodge provisions in the said

policy which may be named Violation and Corresponding Penalties. In case of reported violations on
mandatory requirements and procedures, the DPRM, with the creation of an independent
investigating body under its directorate, shall investigate such reported case and sentence the
applicant who defraud the system as well as the governing board who consented to the fraudulent
activity. This action is in harmony to the principle of integrity and honesty, in which the PNP
institution is known to have highly possessed. Further, these provisions on violations and penalties
will act as a preventive measure or declaratory relief prior staining the unabridged and exquisitely
crafted policy yet.

In comparison, with the existing policy, the same has no concrete provisions on
violations and illicit circumvention on the drafted rules and procedures. Thusly, the benefits are
evident since a policy sans penalties serves no spirit of stability ergo futile. The cost of the said
particular provisions of violations with corresponding penalties causes no damage since the damage
being avoided, the harms of defilements, are far greater than the cost of thwarting the future damages
anticipated.

PNP MEMORANDUM CIRCULAR 2013-014 shall pursue a more rigid

implementation and execution. Unquestionably, the policy itself is uncorrupted, however, it is the
practice and the execution which draw flaws on the system. As above-mentioned actual observations

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 of desecrations, harms and abuses are presently practiced. On the onset, the memorandum circular
confers no penalties yet if any of its provision will be violated. Penalties are designed to reprimand
and correct the any unauthorized and prohibited actuations, hence an alternative policy of augmenting
a more stringent rules would also augment the assurance of compliance.

VII

THE ALTERNATIVE POLICY

PNP MEMORANDUM CIRCULAR 2018-011 the alternative policy with respect to the
placement and promotion system for police commissioned. The following tasks shall be performed by
DPRM, thru its creation of an independent investigating body under its directorate, in preventing
probable circumvention of the promotion and placement system.

a. Directorate for Personnel and Records Management (DPRM)

1) Shall act as Head, Secretariat of the SOPPB; consolidate all evaluation ratings
of the different directorates;
2) Office of Primary Responsibility (OPR) for the criteria (a) Seniority and (b)
Awards, Recognition and Fitness; evaluate the candidates based on the said
criteria;
3) Prepare List of Eligibles;
4) Issue and implement orders for relief and designation.

5) The DPRM shall create an independent investigating body which shall be

under its supervision.

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 i. The investigating body shall be composed of four (4) members and one (1)
chairman.

ii. The investigating body will act on all reported cases or incidents regarding
violations of any provisions in the policy of placement and promotion system;

iii. The investigating body shall have five (5) days to investigate such reported case and
shall accord due process to the parties involved;

iv. The investigating body shall give a notice to the involved parties regarding the
complaint against them and thereafter provide them the opportunity to file and
answer in writing and defend themselves, such answer shall be filed not more than
one (1) day after receipt of the notice of complaint;

v. The investigating body shall make a resolution after the answer has been filed and
send a copy of such resolution both to the involved parties and the Director of
DPRM.

vi. Provided that acting as quasi-judicial body, the investigating body under the
supervision of DPRM, shall not motu proprio file a case against any personnel
regarding their violations to the policy. Therefore, a party must file a complaint
before the investigating body commence to operate; and

vii. Provided further, that the penalty to be imposed shall not exceed PhP10, 000 and/or
shall not be more than one (1) month suspension.

PNP MEMORANDUM CIRCULAR 2013-014 shall pursue a more rigid

implementation and execution. In response on the actual observations of defying the lawful procedure
governing the placement of second level uniformed personnel. The DPRM, thru its creation of an
independent investigating body under its directorate, in preventing probable circumvention of the
promotion and placement system of second level uniformed personnel.

The Directorate for Personnel and Records Management (DPRM).

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 1. Shall act as the primary responsible officer to supervise the proper
implementation of this PNPMC;

2. Act as the approving authority and issue the corresponding order for
transfer/detail of personnel from one PRO to another or to the NSUs and
NHQ;

3. Recommend to the CPNP the detail of personnel outside the PNP;

4. The DPRM shall create an independent investigating body which shall be

under its supervision.

i. The investigating body shall be composed of four (4) members and one (1)
chairman.

ii. The investigating body will act on all reported cases or incidents regarding
violations of any provisions in the policy of placement and promotion system;

iii. The investigating body shall have five (5) days to investigate such reported case and
shall accord due process to the parties involved;

iv. The investigating body shall give a notice to the involved parties regarding the
complaint against them and thereafter provide them the opportunity to file and
answer in writing and defend themselves, such answer shall be filed not more than
one (1) day after receipt of the notice of complaint;

v. The investigating body shall make a resolution after the answer has been filed and
send a copy of such resolution both to the involved parties and the Director of
DPRM.

vi. Provided that acting as quasi-judicial body, the investigating body under the
supervision of DPRM, shall not motu proprio file a case against any personnel
regarding their violations to the policy. Therefore, a party must file a complaint
before the investigating body commence to operate; and

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 vii. Provided further, that the penalty to be imposed shall not exceed PhP 10, 000 and/or
shall not be more than one (1) month suspension.

VIII.

MONITORING AND EVALUATION

IMPACT ANALYSIS: COST AND BENEFIT ANALAYSIS

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 ALTERNATIVE POLICY COST AND BENEFIT
ANALAYSIS
The cost of the alternative
PNP MEMORANDUM CIRCULAR analysis is the increase and
2018-011 and PNP MEMORANDUM amplification of roles with regards
CIRCULAR 2013-014 to the DPRM and DI, acting as ex-
officio body in the investigation of
any violation concerning
promotion and placement of
uniformed personnel.
Nevertheless, the
incomparable benefit of
maintaining the integrity of the
PNP organizations in terms of
placement, promotion, and
reassignment is incomparable, not
to mention the assurance of
system of merit to be
implemented which eradicates the
“palakasan” system.
The penalties of suspension
plus the damages would serve as a
stern warning to the present
unlawful activities in the
promotion and would be a
standing caution on prospective
anticipated future violations.

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