A temporary appointment does not automatically erase the years you worked in the Philippine government. Temporary service is generally included in government service length, particularly for GSIS retirement, leave credits, loyalty awards, and certain salary step increments. However, the result depends on why the length of service is being calculated, whether the appointment was valid, whether an employer-employee relationship existed, and whether the service was properly recorded and covered by GSIS.

Are Temporary Employee Years Counted as Government Service?

The practical answer is usually yes.

Under the GSIS Act of 1997, Republic Act No. 8291, GSIS membership is compulsory for government employees receiving compensation who have not reached compulsory retirement age, regardless of employment status. This generally includes employees holding temporary appointments. (GSIS)

Temporary service may therefore be counted differently depending on the benefit involved:

Purpose of computation	Are temporary years included?	Important condition
GSIS retirement and the 15-year service requirement	Generally yes	The appointment and service must be valid and creditable
GSIS separation benefit	Generally yes	Subject to GSIS service and contribution records
Step increment based on length of service	Yes, in qualifying cases	Usually must be continuous service in the same position
Vacation and sick leave credits	Yes	Credits are based on actual service
Loyalty award	Generally yes	Service must satisfy continuity and performance requirements
Security of tenure	No	Temporary service does not become permanent merely through time
Job order or contract of service work	Generally no	These arrangements ordinarily have no employer-employee relationship

The most common mistake is treating a temporary appointment as if it were the same as a job order or contract of service. They are legally different.

What Is a Temporary Appointment in the Philippine Government?

A temporary appointment is an actual civil service appointment, usually to a regular plantilla position.

Under Section 27 of the Administrative Code of 1987, or Executive Order No. 292, a temporary appointment may be issued when:

no qualified civil service eligible is available;
filling the vacancy is necessary in the public interest;
the appointee meets the education, training, experience, and other requirements of the position; and
the appointee lacks only the appropriate civil service eligibility.

A temporary appointment normally cannot exceed 12 months and may end earlier when a qualified eligible becomes available. The current 2025 Omnibus Rules on Appointments and Other Human Resource Actions continues this framework. (Lawphil)

Temporary appointment versus job order or contract of service

A person with a temporary appointment is ordinarily:

appointed to a government position;
paid through government payroll;
issued an appointment paper;
subject to Civil Service rules;
entitled to applicable leave and personnel benefits; and
compulsorily covered by GSIS, unless a specific exclusion applies.

A job order or contract of service worker, by contrast, is usually engaged to perform a specific task or service without an employer-employee relationship. Republic Act No. 8291 expressly excludes contractual workers who have no employer-employee relationship with the agency. (Google Sites)

Someone who worked for an LGU for five years under job order contracts cannot automatically claim five years of GSIS government service. If that person later received a valid temporary appointment, the period beginning with the temporary appointment may be creditable even though the earlier job order period was not.

Do Temporary Years Count Toward the 15-Year GSIS Retirement Requirement?

In most current cases, yes.

Retirement under Republic Act No. 8291 generally requires that the member:

has rendered at least 15 years of government service;
is at least 60 years old upon retirement; and
is not receiving a permanent total disability pension from GSIS.

Compulsory retirement ordinarily occurs at age 65, subject to limited extensions allowed under Civil Service rules. (GSIS)

Section 10 of Republic Act No. 8291 provides that service is computed from the employee’s original appointment or election. It may include periods served at different times and under one or more government employers. The law does not state that only permanent service can be counted. (GSIS)

Example: temporary service followed by permanent service

Suppose an employee has:

4 years under valid temporary appointments; and
11 years under a permanent appointment.

The employee may generally have 15 years of government service for purposes of GSIS retirement, provided the temporary service is recognized as creditable and is supported by appointment, service, payroll, and GSIS records.

A break in government service does not necessarily erase earlier years

For GSIS retirement, the years do not always have to be continuously served.

For example:

5 years in a national government agency;
a 3-year break;
10 years in an LGU.

Those separate periods may generally be added because Republic Act No. 8291 recognizes service rendered at different times under one or more employers. However, years for which retirement or separation benefits were already awarded may be excluded from a later computation. The Supreme Court applied this principle in GSIS v. De Leon, G.R. No. 217949, February 20, 2019, and Aniñon v. GSIS, G.R. No. 190410, April 10, 2019. (Supreme Court E-Library)

Why Temporary Service Sometimes Does Not Appear in GSIS Records

Being legally creditable and being correctly posted in the GSIS database are not always the same thing.

A temporary employee’s years may be missing because:

the agency did not enroll the employee promptly;
personal or government premium shares were not remitted or were posted under the wrong number;
the employee used different names or membership numbers;
old appointment papers were not transmitted to the Civil Service Commission;
the service record omitted an earlier temporary appointment;
the former agency was abolished or reorganized;
leave without pay was not properly identified; or
the period predates the current GSIS law.

The GSIS Touch mobile application allows members to view membership and service records. A missing entry should be raised with both the agency’s human resource office and the agency’s GSIS-authorized officer or finance unit. (GSIS)

Missing contributions require careful investigation

GSIS benefits operate through a contribution-based social insurance system. Courts have recognized that premium payments can be necessary before earlier service is credited, particularly when contributions had previously been refunded to the employee. (Supreme Court E-Library)

The employee should determine whether:

deductions were actually taken from the salary;
the agency remitted both the employee and employer shares;
the payments were posted under the correct GSIS membership number; and
any premiums were previously refunded when the employee separated.

A blank GSIS record does not, by itself, establish that the employee never rendered government service. It may indicate a record or remittance problem that the agency must reconcile.

Special Rules for Government Service Before June 24, 1997

Republic Act No. 8291 took effect on June 24, 1997. Temporary, casual, contractual, or other non-permanent service before that date may be affected by earlier retirement laws, GSIS premium policies, refund records, or a special agency charter.

Old temporary service should not be assumed to be automatically included or excluded.

Relevant questions include:

Was the employee covered by the GSIS law then in force?
Were retirement premiums deducted and remitted?
Were the premiums later refunded?
Did an agency charter restrict retirement credit to permanent service?
Was the employee subsequently re-employed?
Were earlier separation or retirement benefits already received?

GSIS has decided individual cases in which historical temporary service was excluded because the governing charter or retirement rules at the time did not recognize it. These decisions demonstrate why pre-1997 claims require examination of the actual appointment papers, premium history, and law applicable during the period concerned. (GSIS)

Temporary Service and Salary Step Increments

Temporary years can count toward a step increment in the proper circumstances.

Under CSC-DBM Joint Circular No. 1, series of 2012, one step increment based on length of service may be granted for every three years of continuous and satisfactory service in the present position.

The circular expressly allows the computation to include service rendered:

while holding temporary or provisional status in the same position;
before the position was reclassified, upgraded, or reallocated; and
before reappointment to the same or a comparable position under an approved reorganization.

Thus, an employee who served two years temporarily and then one year permanently in the same position may potentially complete the three-year requirement, assuming satisfactory performance and compliance with the other conditions.

This is different from GSIS retirement. A step increment generally requires continuous service in the present position, while GSIS retirement can include separate government service periods.

Temporary Employees Earn Leave Credits

Temporary government employees are generally entitled to vacation and sick leave credits.

Under CSC Memorandum Circular No. 14, series of 1999, government employees—whether permanent, temporary, or casual—who work during prescribed office hours are entitled to:

15 days of vacation leave annually; and
15 days of sick leave annually.

The normal monthly earning rate is 1.25 vacation leave credits and 1.25 sick leave credits, subject to the rules on actual service and leave without pay.

The fact that an appointment later expires does not make properly earned leave credits fictitious. However, whether the credits are carried forward, transferred, or paid as terminal leave may depend on continuity of service, whether the employee was reappointed, and whether the credits were previously commuted or paid.

Temporary Service and Loyalty Awards

Temporary service may also be included in computing a government loyalty award.

CSC rules provide loyalty awards for officials and employees who complete the required period of continuous and satisfactory government service. The Civil Service Commission has specifically explained that service under a temporary appointment is government service and may be included for loyalty-award purposes. (Civil Service Commission)

Continuity remains important. For example, a lengthy gap between appointments or excessive leave without pay may affect qualification even though the same periods would still remain part of the employee’s overall GSIS service history.

Temporary Service Does Not Create Security of Tenure

Counting temporary years for retirement or benefits does not convert a temporary employee into a permanent employee.

A temporary appointee generally:

has no permanent security of tenure;
may be replaced when a qualified eligible becomes available;
has no automatic right to renewal after the appointment expires; and
does not automatically acquire permanent status by passing a civil service examination.

A new permanent appointment must still be lawfully issued by the appointing authority. The Supreme Court has repeatedly ruled that temporary appointments do not confer the same security of tenure enjoyed by permanent appointees. (Lawphil)

This distinction can feel unfair to an employee who has worked continuously for many years, but the legal rules on tenure and the rules on creditable service address different questions.

When Temporary Years May Be Excluded

Temporary service may be excluded when:

The appointment was disapproved or invalidated. Under the 2025 appointment rules, service rendered after receipt of a notice rejecting or disapproving an appointment may not be considered government service. Certain appointments that required but never obtained lawful concurrence may also be treated as ineffective. (Civil Service Commission)
There was no actual temporary appointment. An office ID, memorandum, payroll entry, or verbal instruction is not necessarily a civil service appointment.
The worker was actually under job order or contract of service. These arrangements ordinarily lack the employer-employee relationship required for GSIS coverage.
The same service was already used for benefits. Service for which retirement or separation benefits were awarded cannot simply be counted again.
Premiums were refunded. Restoring the corresponding service may require repayment where legally permitted.
The service is governed by a special retirement law or charter. Judges, constitutional commissioners, military or uniformed personnel, and employees covered by special charters may be subject to different rules.
The employer was a non-chartered GOCC. Employees of a government corporation without an original charter may be governed by the Labor Code and SSS rather than ordinary Civil Service and GSIS rules. (Lawphil)

How to Verify and Correct Your Government Service Length

1. Identify why your service is being computed

Ask whether the issue concerns:

GSIS retirement;
separation benefits;
leave credits;
terminal leave;
a step increment;
a loyalty award;
seniority; or
qualification for another personnel benefit.

The rules are not identical for each purpose.

2. Obtain a certified service record

Request a certified Service Record from the current or former agency’s Human Resource Management Office. It should show:

complete name and previous names used;
position title;
appointment status;
inclusive dates of service;
salary;
office or station;
periods of leave without pay; and
dates of separation, transfer, or reappointment.

3. Collect the appointment documents

Useful supporting records include:

Document	Why it matters
Appointment paper, usually CS Form No. 33	Proves the status and effective dates of the appointment
CSC action, validation, or appointment transmittal record	Helps establish that the appointment was not disapproved
Oath of office and assumption-to-duty certification	Confirms when actual service began
Payslips and payroll certifications	Prove compensation and salary deductions
Daily time records or personnel records	Support actual service
GSIS Member Service Profile	Shows what GSIS currently recognizes
Premium remittance certification	Identifies unposted or unpaid contributions
Previous benefit or refund records	Determines whether earlier service was already used

4. Compare agency records with GSIS records

Use GSIS Touch or obtain a membership record from GSIS. Mark every missing month or year and compare it with the certified service record.

Do not rely only on the total number of years displayed. Check:

the date of original appointment;
all former employers;
temporary appointment periods;
periods of leave without pay;
remittance gaps; and
any previous separation-benefit payment.

5. Request a written reconciliation

Submit copies to the agency HR office, finance unit, and GSIS-authorized officer. Ask them to certify:

whether the appointment was valid;
whether premiums were deducted;
when the premiums were remitted;
the GSIS reference numbers used; and
whether a correction or remittance adjustment was transmitted.

A straightforward current-agency correction may take several days or weeks. Cases involving an old LGU, abolished office, mismatched membership number, missing appointment paper, or pre-1997 service can take several months. These are practical estimates, not fixed legal processing periods.

6. Obtain a formal GSIS determination if the issue remains disputed

For retirement or separation claims, GSIS commonly requires a Service Record with a certification identifying the dates of leave without pay. Current filing information appears on the GSIS online filing of claims page. (GSIS)

If GSIS excludes the temporary period, request a written decision explaining:

the specific period excluded;
the legal or policy basis;
whether premiums were missing or refunded; and
what documents or payments would cure the deficiency.

7. Observe appeal deadlines

A disputed claims decision may be elevated through the GSIS claims-adjudication process, including an appeal to the GSIS Board of Trustees. A final Board decision may be reviewed by the Court of Appeals through a petition under Rule 43 of the Rules of Court, generally within 15 days from notice, subject to the applicable procedural rules. Missing the appeal period can make the decision final. (GSIS)

Common Real-Life Scenarios

Repeated one-year temporary appointments

Several successive temporary appointments can produce several years of government service. Each appointment should nevertheless be checked for validity, effective dates, CSC action, and GSIS remittances.

Repeated temporary appointments do not automatically create permanent status, but the actual periods legally served may still count toward applicable benefits.

Job order followed by a temporary appointment

Only the period covered by the temporary appointment will ordinarily be treated as civil service and GSIS-covered employment. The earlier job order period usually does not count because there was no employer-employee relationship.

Transfer from one agency to another

Temporary service in one agency and permanent service in another may generally be combined for GSIS retirement. For a step increment, however, the employee must satisfy the narrower requirement concerning service in the same or comparable position.

Previous private-sector employment

Private employment is not converted into government service. However, Republic Act No. 7699, the Limited Portability Law, may permit totalization of SSS contributions and GSIS creditable service when the employee cannot independently satisfy the eligibility requirements of either system. Overlapping periods are not counted twice. (Social Security System)

Former government employee now living abroad

A former employee abroad can request records directly from the former agency and GSIS. When appointing a representative in the Philippines, the agency may require a special power of attorney and identification documents. A document executed abroad may need acknowledgment before a Philippine consular officer or an apostille, depending on the country of execution and the receiving agency’s current requirements.

Frequently Asked Questions

Do temporary years count toward the 15 years required by GSIS?

Generally, yes. Republic Act No. 8291 covers government employees regardless of employment status, and creditable service may include periods under temporary appointments.

Can an agency exclude my years simply because I was not permanent?

Not on that reason alone. The agency or GSIS must consider whether the appointment was valid, the service was actually rendered, and the period was creditable under the applicable law.

What if GSIS contributions were deducted but do not appear in my record?

Obtain payroll and remittance certifications from the agency. Ask the agency’s GSIS-authorized officer to trace the deductions and request correction of the posting.

Does a gap between appointments reset my GSIS service to zero?

No. Separate periods can generally be added for GSIS retirement. A gap may nevertheless affect benefits requiring continuous service, such as certain step increments or loyalty awards.

Does ten years as a temporary employee make me permanent?

No. Length of temporary service does not automatically confer permanent status or security of tenure. A valid permanent appointment must be issued.

Do temporary employees earn vacation and sick leave?

Generally, yes. Temporary government employees covered by the leave rules earn vacation and sick leave credits based on actual service.

Can temporary service count toward a salary step increment?

Yes, when it was rendered in the same position and the employee satisfies the continuous and satisfactory service requirements under CSC-DBM rules.

Can job order years be converted into temporary government service?

Generally, no. A job order contract cannot ordinarily be retroactively converted into an appointment. The actual appointment paper and legal employment relationship control.

What if my temporary service was before 1997?

The applicable older retirement law, premium history, agency charter, refund records, and later reemployment must be reviewed. Pre-1997 service requires a case-specific determination.

What should I do if GSIS denies inclusion of my temporary years?

Secure the written decision, review the reason for exclusion, submit the appointment and contribution records, and observe the deadlines for appeal to the GSIS Board and, when applicable, the Court of Appeals.

Key Takeaways

Temporary government service generally counts, especially for GSIS retirement, leave credits, loyalty awards, and qualifying step increments.
A temporary appointment is legally different from a job order or contract of service.
Temporary years can generally help satisfy the 15-year GSIS retirement requirement.
Breaks in service do not necessarily erase earlier GSIS-creditable years.
Temporary service does not create permanent status or security of tenure.
Invalid appointments, refunded premiums, prior benefit payments, missing contributions, special charters, and pre-1997 service can affect the computation.
The most important records are the appointment paper, certified Service Record, CSC action, payroll documents, and GSIS premium history.
Any exclusion should be obtained in writing because GSIS appeal periods are strictly observed.