Below is a comprehensive discussion of permanent employment eligibility for co-terminous barangay personnel in the Philippine context. This article synthesizes the key laws, administrative rules, and jurisprudential guidelines that govern co-terminous appointments at the barangay level and clarifies when, if at all, these positions can enjoy permanent employment status.

1. Defining “Co-terminous Barangay Personnel”

In Philippine public service parlance, “co-terminous” employees are those whose tenure or period of employment is explicitly tied to:

The term or tenure of the appointing official;
The lifespan of an office or organizational unit; or
A specific project with a pre-determined completion date.

Within the barangay context (the smallest local government unit under Republic Act No. 7160, or the Local Government Code of 1991), co-terminous personnel usually serve at the pleasure of the Punong Barangay (Barangay Chairperson), or for as long as that elected official remains in office. When the Punong Barangay’s term ends, the service of these co-terminous employees also ends, unless reappointed by the incoming official.

2. Legal Basis and Nature of Barangay Personnel

2.1. Local Government Code of 1991 (R.A. 7160)

Sections 387–442 of R.A. 7160 outline the structure and officials of the barangay. Key mandatory positions include:
- Punong Barangay (Barangay Chairperson)
- Sangguniang Barangay Members (Barangay Councilors)
- Sangguniang Kabataan Chairperson (and SK Members for youth-related matters)
- Barangay Secretary
- Barangay Treasurer

The Code provides that the Punong Barangay may appoint certain personnel (e.g., barangay secretary, barangay treasurer, and other barangay staff, as may be necessary) subject to the approval of the Sangguniang Barangay. These appointments, if designated as co-terminous, generally align with the term of the Punong Barangay.

2.2. Civil Service Commission (CSC) Regulations

The Civil Service Commission classifies positions in government into Career Service and Non-Career Service.
- Career Service employees typically go through a competitive examination process (or equivalent) and enjoy security of tenure once appointed on a permanent status.
- Non-Career Service employees—such as those holding co-terminous appointments—generally do not enjoy permanent status because their positions are inherently tied to a specific term or condition.

Under various CSC Memorandum Circulars (e.g., CSC MC No. 14, s. 2018, and earlier MCs on appointments and eligibility), co-terminous employees:

Do not acquire security of tenure beyond the period specified in their appointment.
May not be reclassified as “permanent” if the position is inherently co-terminous.

3. Can Co-terminous Barangay Personnel Obtain Permanent Employment?

3.1. Distinction Between Position Classification and Eligibility

A crucial point is distinguishing between:

Eligibility (i.e., passing the appropriate civil service examination or being granted eligibility under special laws), and
Nature of Appointment (i.e., permanent, temporary, co-terminous, contractual, casual, etc.).

Even if a barangay staff member possesses the required civil service eligibility, the appointment can still be co-terminous if the position classification itself is co-terminous. The term “permanent” under civil service rules pertains to an appointment that provides the appointee with security of tenure if the position is a career position and is not tied to the term of an elective official or a project-based condition.

In other words, having eligibility does not automatically convert a co-terminous position into a permanent one. Co-terminous positions, by their very nature, end when the cause or basis for the appointment (e.g., the appointing official’s term) ceases.

3.2. Barangay Secretary and Barangay Treasurer

Although the Barangay Secretary and Barangay Treasurer are mandatory positions, the Local Government Code stipulates that they serve upon appointment by the Punong Barangay and concurrence of the Sangguniang Barangay.
Case references and CSC rulings indicate that these positions often remain co-terminous with the Punong Barangay, unless the local government unit (LGU) has explicitly classified them otherwise (which is rare for barangays, given the LGC structure).

3.3. Possibility of Regular or Career Appointments

In practice, some local government units above the barangay level (e.g., municipalities, cities, provinces) have positions that are career or permanent in nature. However, at the barangay level, most staff beyond the mandated positions (secretary and treasurer) are either:

Job-order or casual employees paid through local funds for specific tasks; or
Co-terminous staff employed through the Punong Barangay’s discretionary hires.

Because of this, “permanent” appointments at the barangay level are either non-existent or very rarely granted in standard practice. If a co-terminous position is reclassified as a career position (a process requiring the CSC’s and the DBM’s approval to change the Plantilla of Personnel), only then could a holder of that position be appointed permanently—provided the appointee also meets the eligibility and qualification requirements.

4. Security of Tenure and Termination of Co-terminous Personnel

4.1. Security of Tenure Limits

The Supreme Court and the Civil Service Commission have consistently held that co-terminous employees do not enjoy the same security of tenure as permanent employees in the career service. Their tenure ends when:

The official who appointed them leaves office (through expiration of term, resignation, dismissal, or any other mode);
The project or program for which the appointment was made has ended; or
The appointing authority decides to remove them at any time, if the co-terminous appointment is stated to be at the “pleasure” of that authority.

4.2. Due Process Considerations

While co-terminous employees’ tenure ends automatically with the term of their appointing official, the Civil Service Commission typically expects at least minimal due process if an earlier termination occurs. Still, the scope of due process for co-terminous personnel is more limited compared to those holding permanent or career positions.

5. Relevant Jurisprudence and CSC Issuances

Civil Service Commission vs. Salas (G.R. No. 110026) – Emphasizes that an appointment is co-terminous when made coterminous with the project, the official, or the program. Security of tenure is limited by that condition.
CSC Issuances (Memorandum Circulars) – Reiterate that for one to enjoy permanent status, the position must be part of the career service, the incumbent must meet the qualification standards (including eligibility), and the position must not be inherently co-terminous.
Local Government Code Interpretative Guidelines – The Department of the Interior and Local Government (DILG) and the CSC often issue joint memoranda clarifying that barangay personnel, such as the secretary and treasurer, typically remain under co-terminous status with the Punong Barangay.

6. Practical Implications for Barangay Governance

Turnover with New Leadership
Because barangay personnel often serve co-terminously with the Punong Barangay, there can be high turnover when leadership changes following barangay elections.
Impact on Professional Development
Personnel seeking long-term stability often look to career positions in higher LGUs (municipal, city, provincial offices) or in national government agencies. While working in a barangay co-terminous role can be a stepping stone, it does not normally lead to permanent civil service status.
Appointment Documentation
Barangay officials and appointees must ensure that the nature of the appointment—whether co-terminous, casual, or contractual—is clearly spelled out in official documents. This clarity protects both the appointee and the LGU from disputes regarding the length or terms of service.
Local Budgets and Funding
Co-terminous positions typically rely on the barangay’s internal revenue allotment (IRA) and other local funds. Budget constraints sometimes limit the number and duration of co-terminous hires.

7. Conclusion

Co-terminous barangay personnel in the Philippines generally cannot hold permanent employment status because:

Their positions are inherently tied to the term of the Punong Barangay or another condition specified by law.
Even when they possess the requisite civil service eligibility, the nature of the position remains non-career, hence no entitlement to permanent appointment.
The Local Government Code of 1991, CSC regulations, and jurisprudence consistently affirm that co-terminous employees do not enjoy security of tenure beyond the tenure of their appointing official.

That said, theoretical exceptions could arise if the barangay (through approved reclassification and proper budget allocation) creates and approves a career or regular position. In such a rare instance, a qualified and eligible candidate could be appointed on a permanent status, but this is atypical for barangay offices. Generally, barangay positions remain electively mandated or co-terminous, and those serving in these positions must be prepared for the possibility of turnover with changes in local leadership.

Overall, anyone hired as co-terminous barangay personnel should be mindful that their employment is bound to the term, authority, or program from which their appointment draws its legal life. They should not rely on an expectation of indefinite tenure or permanence unless the position undergoes a formal reclassification to a career service post—a process governed by stringent CSC and DBM rules and local legislation, and not commonly undertaken at the barangay level.