The officer died trying to rescue those trapped in the blaze at the four-storey NCCC mall in Davao City on Saturday, the operators said.
Also killed were 37 employees of a 24-hour call centre for US-based market research firm SSI on the top floor of the building.
Mayor Sara Duterte, the daughter of Philippine President Rodrigo Duterte, said one SSI employee is counted among the dead even though her body has not yet been recovered.
NCCC mall spokeswoman Thea Padua said in a statement today that "we categorically deny the allegations that we do not have enough fire exits, extinguishers, sprinklers and designated fire escapes. We have been fully compliant with the labour standards."
The cause of the blaze has still not been determined. The justice and labour departments and Davao's fire-fighting bureau have ordered separate investigations.