Director Enrique Galang, PNP directorial staff chief, said the 120 available posts for senior superintendents might not be filled up.
Only 31 police officers have passed the Civil Service Executive Eligibility (CSEE) tests, sources said.
Director Lucas Managuelod, former Directorate for Investigation and Detective Management chief, said under Republic Act 6975, the National Police Commission (Napolcom) has the "exclusive jurisdiction" to administer promotional examinations for police officers.
Managuelod, a lawyer, said Napolcom "erred" in issuing Resolutions Nos. 2002-034 and 97-218 requiring senior police officers to take the CSEE and CSE.
"Let us think of the welfare of the personnel... it’s time we let go of personal interests and think about the organization," he said.
Managuelod said the petition for a writ of preliminary injunction he filed two years ago to stop implementation of the Napolcom resolutions had not been acted upon by the Court of Appeals.
"(Implementation of the two Napolcom resolutions) will not cause tremendous awry in peace and order campaign of the PNP... but indubitably inflict irreparable damage and injury to incumbent officers," he said.
Managuelod said since 2002, many police officers due for promotion have not been CSEE and CSE eligible.
"Upon the implementation of the assailed resolutions, a hiatus within the PNP would likely occur pending the qualification of almost all of its senior officers as CSEE and CSE eligible," he said.
The promotions of some police generals without CSEE and CSE eligibility after 2002 are now at risk of being questioned, he added.
Of the three-star rank police generals, only Deputy Director General Virtus Gil, PNP deputy chief for operations, has reportedly passed the CSE.
Meanwhile, Galang said about 8,343 policemen might face dismissal for failing to get a college degree as mandated by Republic Act 8551.
It would cost the government some P600 million to train a new batch of police rookies, he added.
Galang said a PNP study showed it would take another 15 years for the new policemen to be trained in the rudiments of police service.
"Already most of these 8,343 have been trained and they have developed their management and operational skills through years of experience, they merely lack educational requirements," he said.
"Their attrition would affect the operations of the entire police organization."
The directorial staff had already submitted its findings and its recommendations to Interior and Local Government Secretary Angelo Reyes, he added.
Reyes said a technical working group comprised of representatives of the Napolcom, the CSC and the PNP will look into the "specific concerns," particularly those affecting the rank and file.