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Employees paid on a purely commission basis are not entitled to 13th month pay.
They are expressly excluded from the coverage of PD 851.
The Labor Code distinguishes a rank-and-file employee from a managerial employee.
It provides that a managerial employee is one who is vested with powers of prerogatives to lay down and execute management policies and/or to hire, transfer, suspend, lay-off, recall discharge, assign or discipline employees, or to effectively recommend such managerial actions.
I will comment them once blogging resumes in January.