An employer generally cannot require an employee to spend personal money on company raffle tickets, shoulder the cost of unsold tickets, or allow the ticket price to be deducted from salary simply because management imposed a quota. Philippine labor law strictly limits wage deductions and prohibits employers from using force, threats, or intimidation to make workers surrender part of their wages.

A different rule may apply when employees are merely asked to promote or sell raffle tickets during paid working hours. An employer may assign reasonable, lawful, work-related tasks without paying a separate commission unless a commission is promised by the employment contract, collective bargaining agreement, company policy, incentive plan, or established company practice.

The key questions are therefore:

Is the employee being asked to sell tickets or personally buy them?
Will unsold tickets be charged to the employee?
Will the amount be deducted from wages?
Was a commission promised?
Is refusal being met with threats, penalties, poor evaluations, suspension, or dismissal?

Can a Company Force Employees to Buy Raffle Tickets?

As a general rule, no. An employer cannot automatically treat company raffle tickets as a personal financial obligation of its employees.

Employees earn wages in exchange for their work. Management normally cannot redirect those wages back to the company by requiring workers to purchase tickets, products, merchandise, uniforms, fundraising items, or other company-sponsored materials unless the arrangement is lawful and genuinely voluntary.

The legal problem becomes especially serious when the employer:

Gives each employee a fixed number of tickets and declares them “sold” immediately;
Requires employees to pay for tickets even when they cannot find buyers;
Deducts the ticket cost from payroll;
Refuses to release wages until the tickets are paid;
Requires employees to sign salary-deduction forms under pressure;
Threatens suspension, dismissal, poor performance ratings, or loss of work schedules;
Publicly shames employees who do not meet the quota; or
Describes the purchase as voluntary but imposes consequences on anyone who refuses.

Calling the program a “company activity,” “fundraiser,” “team contribution,” or “mandatory support” does not change its legal effect. Authorities will look at what actually happened, not merely the label used by the employer.

Philippine Labor Law on Salary Deductions

Article 113 of the Labor Code

Article 113 of the Labor Code provides that an employer cannot deduct amounts from an employee’s wages except in limited situations, including deductions authorized by law, certain insurance premiums, and properly authorized union dues. (Lawphil)

The Omnibus Rules Implementing the Labor Code also allow deductions made with an employee’s written authorization for payment to a third person, provided the employer does not receive a direct or indirect financial benefit from the transaction. (Lawphil)

This creates an important problem for compulsory company raffle tickets: the company, its officers, or its chosen beneficiary may be receiving the money. A signed payroll authorization does not automatically make the deduction valid when:

The employee signed because of pressure or fear;
The employer directly benefits from the ticket sale;
Refusal would affect the employee’s job;
The employee was not given a real choice;
The form did not clearly state the amount and purpose; or
The authorization was obtained only after the deduction had already been made.

In Lingcord Listing Corporation v. Genovia, the Supreme Court emphasized that withholding or deducting wages is permissible only under the circumstances allowed by Article 113 and its implementing rules. The Court ordered the reimbursement of unauthorized deductions where there was no written conformity from the employees. (Lawphil)

Article 116: Forced Surrender of Wages Is Prohibited

Article 116 of the Labor Code makes it unlawful to withhold wages or induce a worker to give up part of those wages through force, stealth, intimidation, threat, or any other means without the worker’s consent. (Lawphil)

This provision may apply even when the employer does not technically enter a “deduction” on the payslip. For example, management may release the full salary but require the employee to return ₱1,000 in cash for raffle tickets. If the payment was compelled through threats or workplace pressure, the arrangement may still amount to forcing the employee to surrender part of the employee’s wages.

Consent must be real. A payment is not necessarily voluntary merely because the employee:

Handed over cash;
Signed an acknowledgment receipt;
Accepted the tickets;
Did not immediately complain; or
Continued reporting for work.

The employee may have complied because refusing a supervisor’s instruction appeared likely to endanger the employee’s livelihood.

Selling Raffle Tickets Is Different From Buying Them

An employer may sometimes assign employees to distribute, market, or sell raffle tickets as part of a company event. This is not automatically illegal.

Under the doctrine of management prerogative, an employer generally has discretion over work assignments, methods, supervision, schedules, and business operations. However, management prerogative must be exercised reasonably, lawfully, in good faith, and without violating wages, benefits, security of tenure, or other employee rights. (Lawphil)

The following situations should be distinguished:

Workplace arrangement	Likely legal effect
Employee voluntarily buys one ticket using personal money	Generally valid if consent is genuine
Employee is asked to promote tickets during paid working hours	May be a lawful work assignment
Employee is required to sell tickets but may return unsold tickets without paying	Usually less problematic, subject to reasonable work conditions
Employee must personally pay for all unsold tickets	Strong indication of an unlawful compulsory purchase
Ticket cost is deducted from salary without valid authority	Likely an illegal wage deduction
Employee is promised a commission for each ticket sold	Earned commission should be paid according to the agreement
No commission was ever promised for an occasional, reasonable assignment	Lack of commission is not automatically illegal
Employee is threatened with dismissal for refusing to buy tickets	Serious labor-law concern
Employee is disciplined for refusing a lawful, reasonable selling assignment connected with the job	May be valid, depending on the facts and due process

The dividing line is usually whether the employer is assigning work or transferring the company’s financial risk to the employee.

A company may ask an employee to contact customers or promote an event. It should not ordinarily make the worker the guaranteed buyer of whatever the worker cannot sell.

Is the Employee Entitled to a Commission?

Philippine law does not establish a universal rule requiring a commission whenever an employee sells raffle tickets. Commission becomes legally demandable when it forms part of the agreed compensation.

A commission may be enforceable when it is provided in:

The employment contract;
A written incentive or commission plan;
A memorandum announcing the raffle mechanics;
A collective bargaining agreement;
A consistently followed company policy;
Emails or messages promising a stated amount per ticket;
A long-standing company practice; or
A verbal agreement supported by credible evidence.

The Supreme Court has recognized that commissions may form part of an employee’s wage or compensation, particularly when they are paid as remuneration for services. (Lawphil)

Once an employee has completed the conditions for earning a promised commission, the employer cannot simply cancel or withhold it without a contractual or legal basis.

Non-Diminution of Benefits

Article 100 of the Labor Code prohibits the elimination or diminution of benefits. A commission or incentive may become protected when it has been consistently and deliberately granted over a significant period, is not based on an error, and has become part of the employees’ compensation package or established company practice. (Lawphil)

However, not every one-time bonus, discretionary reward, or temporary raffle incentive becomes a permanent benefit. The documents and history of the payment matter.

Can an Employee Be Fired for Refusing?

An employee cannot validly be dismissed merely because management is displeased. Dismissal must be supported by a just or authorized cause under the Labor Code and must comply with procedural due process.

Willful disobedience may be a just cause for dismissal only when:

The employee’s refusal was intentional and showed a wrongful or perverse attitude; and
The employer’s order was lawful, reasonable, made known to the employee, and related to the duties for which the employee was hired.

The Supreme Court applied these requirements in A & L Fishpond and Hatchery, Inc. v. Ariola. (Lawphil)

Refusing a reasonable instruction to distribute tickets during paid work may therefore be different from refusing to spend personal money on those tickets. An order to personally buy company merchandise or shoulder unsold tickets may be challenged as unlawful or unreasonable, especially where it effectively takes away part of the employee’s wages.

Even when management believes an offense occurred, it must normally provide:

A first written notice identifying the accusation and giving the employee a reasonable opportunity to explain;
A genuine opportunity to respond and present evidence; and
A written notice stating the employer’s decision.

A sudden verbal dismissal, removal from the work schedule, or instruction not to return may be evidence of illegal dismissal if no valid cause and proper process exist. (Lawphil)

Retaliation After an Employee Complains

Article 118 of the Labor Code prohibits an employer from reducing wages or benefits, dismissing, or discriminating against an employee for filing a complaint, starting a proceeding, or testifying in a wage-related case. (Lawphil)

Possible retaliatory acts include:

Cutting the employee’s shifts after a complaint;
Removing regular allowances;
Giving fabricated disciplinary charges;
Transferring the employee to a clearly punitive assignment;
Pressuring the employee to resign;
Refusing to release earned commissions; or
Dismissing the employee shortly after the employee sought DOLE assistance.

Timing alone does not automatically prove retaliation, but it can be important when combined with messages, witness statements, inconsistent explanations, or the absence of documented performance problems before the complaint.

What Employees Should Do

1. Clarify the Instruction

Ask management, preferably in writing:

Are employees required to personally buy the tickets?
Can unsold tickets be returned?
Will any amount be deducted from salary?
Is selling mandatory or voluntary?
Is there a commission or incentive?
What written company policy authorizes the program?
What happens if an employee declines?

A clear written answer can prevent the employer from later changing its version of the arrangement.

2. Preserve Evidence

Keep copies of:

Employment contract and job description;
Company handbook and code of discipline;
Raffle mechanics and announcements;
Tickets issued to the employee;
Ticket acknowledgment or liquidation forms;
Payroll-deduction authorizations;
Payslips and payroll records;
Bank or e-wallet payment records;
Emails, text messages, and workplace chat messages;
Notices threatening discipline or dismissal;
Performance evaluations before and after the dispute; and
Names of coworkers who received the same instructions.

Do not secretly alter documents or fabricate screenshots. Preserve the original messages, dates, sender details, and attachments.

3. Object Calmly in Writing

The employee can state:

I am willing to perform reasonable work assignments, including helping distribute or promote the tickets during paid working time. However, I do not consent to personally purchasing unsold tickets or to any deduction from my wages for their cost. Please provide the written policy and legal basis for any proposed deduction.

This wording separates refusal to surrender personal wages from refusal to perform legitimate work.

4. Use the Internal Grievance Process

Submit the concern to human resources, payroll, compliance, the grievance committee, or the employee’s union.

For unionized workplaces, review the collective bargaining agreement. It may contain rules on commissions, payroll deductions, management rights, grievance deadlines, and voluntary arbitration.

5. File a Request for Assistance Under SEnA

The Single Entry Approach, or SEnA, is the usual first government process for many labor disputes. It provides a mandatory conciliation-mediation period intended to encourage settlement before a formal labor case proceeds.

A Request for Assistance may be filed through the appropriate DOLE regional, provincial, or field office. SEnA generally provides up to 30 days for conciliation-mediation. It was established through Department Order No. 107-10 and later strengthened by Republic Act No. 10396. (Department of Labor and Employment NCR)

During SEnA, the employee may request:

Reimbursement of raffle-ticket deductions;
Payment of earned commissions;
Cancellation of the compulsory purchase;
Correction of payroll records;
Withdrawal of retaliatory disciplinary action;
Issuance of a certificate of employment or final pay, when relevant; or
An agreed workplace policy preventing similar deductions.

The employee should bring identification and available employment and payroll records. A complete trial-type presentation is not normally required at the beginning, but organized evidence makes settlement easier.

6. Proceed to the Proper Labor Office if No Settlement Is Reached

The correct forum depends on the type and amount of the claim.

Under Article 129 of the Labor Code, a DOLE Regional Director or authorized hearing officer may decide certain simple money claims not exceeding ₱5,000 per employee, provided reinstatement is not requested. Claims exceeding that amount or involving illegal dismissal and reinstatement generally fall within the jurisdiction of a Labor Arbiter of the National Labor Relations Commission. (Lawphil)

DOLE may also exercise inspection and labor-standards enforcement powers in appropriate cases. Because jurisdiction depends on the exact claims and employment status, the SEnA desk commonly assists in routing unresolved disputes to the proper office.

Evidence and Documents Checklist

Document or evidence	Why it matters
Payslips before and after the raffle	Shows the amount and timing of deductions
Raffle tickets or ticket stubs	Establishes quantity, price, and accountability
Signed salary-deduction form	Shows the wording and circumstances of alleged consent
Messages from supervisors	May prove quotas, threats, or promises of commission
Employment contract and job description	Helps determine whether selling was related to assigned duties
Commission plan or company memorandum	Establishes the agreed rate and conditions
Bank, cash, or e-wallet records	Proves payments made outside payroll
Coworker statements	May show that the practice affected multiple employees
Notices to explain or termination letters	Important in retaliation or illegal-dismissal claims
Written objection and management response	Shows that the employer was informed of the employee’s position

Employees should act promptly. Labor Code money claims generally prescribe after three years from the time the claim accrued. Illegal-dismissal actions generally have a four-year prescriptive period because they are treated as actions involving injury to rights under Article 1146 of the Civil Code. (Lawphil)

What if the Employee Signed a Consent Form?

A signature is important evidence, but it is not always conclusive.

Under Articles 1330 and 1335 of the Civil Code, consent obtained through violence, intimidation, undue influence, fraud, or mistake may be legally defective. Intimidation exists when a person is compelled to agree because of a reasonable and well-grounded fear of an imminent and grave harm to the person or property. (Lawphil)

Workplace pressure does not automatically invalidate every agreement. The surrounding facts must be examined, including:

Whether refusal would realistically threaten the employee’s job;
Whether supervisors demanded immediate signing;
Whether employees could return the tickets;
Whether the amount was clearly disclosed;
Whether the form was explained in a language the employee understood;
Whether employees who refused were punished; and
Whether the employer benefited directly from the deduction.

A form signed freely before a genuinely voluntary purchase is different from a form signed after a supervisor says, “Sign this or do not report tomorrow.”

Does the Raffle Itself Need Government Approval?

The legality of the raffle is a separate question from the legality of charging employees.

Commercial sales promotions involving raffles may require a permit from the Department of Trade and Industry under the Consumer Act and applicable DTI rules. The DTI’s Sales Promotion Division regulates covered promotional campaigns and identifies conventional and electronic raffles as forms of sales promotion. (E-Sigaw)

Employees may ask for the raffle’s permit number, mechanics, sponsor, beneficiaries, drawing date, and accounting rules. However, even a properly permitted raffle does not authorize an employer to make unlawful wage deductions or compel employees to purchase tickets.

Frequently Asked Questions

Can my employer deduct unsold raffle tickets from my salary?

Generally, the employer cannot do so without a valid legal basis. Wage deductions are strictly limited, and written authorization may still be questionable when the employer benefits from the transaction or the employee signed under pressure.

Is it legal to give employees a mandatory raffle-ticket quota?

A sales target may be a reasonable work assignment in some jobs. It becomes legally problematic when employees must personally pay for tickets they cannot sell.

Can I refuse to buy company raffle tickets?

Yes. Employees may object to spending their own wages on company tickets. Make the objection in writing and clarify that you remain willing to perform lawful and reasonable work assignments.

Can I be required to sell tickets without commission?

Possibly. There is no automatic statutory commission for every ticket sold. A commission is due when it was promised by contract, policy, incentive plan, collective bargaining agreement, established practice, or another enforceable arrangement.

What if the tickets are for charity?

A charitable purpose does not automatically make employee purchases compulsory. Donations and purchases should still be voluntary, and wage-deduction rules continue to apply.

What if everyone else agreed to buy tickets?

Other employees’ participation does not remove an individual employee’s rights. The real issue is whether each employee freely consented and whether the employer complied with wage-deduction rules.

Can the employer require payment in cash instead of deducting it from payroll?

Requiring cash does not necessarily solve the problem. Article 116 also prohibits inducing an employee to surrender part of the employee’s wages through force, intimidation, or threats.

Where should I complain first?

Employees commonly begin with the employer’s written grievance process and then file a Request for Assistance through the nearest DOLE SEnA desk. A barangay complaint is generally not the primary process for an employer-employee wage dispute.

Can several employees file together?

Employees affected by the same policy may approach DOLE together or coordinate through their union. Each employee should still prepare an individual computation of deductions, payments, and unpaid commissions.

What can I recover?

Depending on the evidence, an employee may seek reimbursement of illegal deductions, payment of earned commissions, restoration of reduced benefits, legal interest, and remedies for illegal dismissal or retaliation.

Key Takeaways

Employers generally cannot force workers to personally buy raffle tickets or pay for unsold tickets.
Ticket costs cannot simply be deducted from wages because management imposed a quota.
A signed deduction form may be ineffective when consent was pressured or the employer directly benefited.
Asking employees to sell or promote tickets may be a lawful work assignment if it is reasonable, lawful, and related to their duties.
A separate commission is required only when it was promised or became part of the employee’s established compensation.
Refusal to buy tickets is different from refusing a lawful work assignment.
Employees should preserve payslips, tickets, messages, deduction forms, policies, and evidence of threats.
Unresolved disputes may be brought to DOLE through the 30-day SEnA conciliation-mediation process.
Money claims generally must be filed within three years, while illegal-dismissal claims generally prescribe after four years.