Last updated: November 11, 2025 (Philippine context). This is practical legal information, not a substitute for tailored legal advice.

1) Why roaming charges go wrong (and how to spot it)

Common scenarios

Border roaming: Your phone latches onto a foreign tower while you’re still in PH (e.g., vessels off Palawan or Tawi-Tawi, or coastal areas facing Malaysia/Indonesia).
Silent data sessions: Background app updates, cloud sync, voicemail or Wi-Fi Assist features create roaming data even if you didn’t actively browse.
Wrong plan/tier: Roaming add-on wasn’t applied, expired mid-trip, or the operator billed standard pay-per-use instead of the promised “flat-rate roam.”
Duplicate/phantom records: Delayed Call Detail Records (CDRs) from foreign carriers cause double posting or billing on the wrong cutoff.
Exchange-rate mishaps: Foreign-currency roaming bundles converted twice or at the wrong rate.
SIM/eSIM mix-ups: The non-intended SIM stayed “on” for data while traveling.
Premium/short codes: Unexpected charges for incoming SMS/alerts while roaming.
Time-zone cutoff issues: Usage straddling bill cycles and local time vs. network time.

Early warning signs

A “welcome to [country]” SMS when you haven’t left the Philippines.
Sudden data bursts in your phone’s usage logs minutes after landing—often auto-updates.
A bill section labeled International Roaming with rates that differ from your add-on.
Per-MB or per-10KB charges despite an active bundle.

2) The legal framework (plain-English map)

Constitutional policy: Consumers are entitled to protection against deceptive or unfair practices; communications is a regulated public service.
Consumer Act (RA 7394): Guards against deceptive, unfair, or unconscionable sales acts and requires clear price disclosure and warranty of services.
Public Telecommunications Policy Act (RA 7925) & related regulations: Telecoms are public utilities subject to service quality standards, accurate billing, truthful advertising, and regulatory oversight.
Mobile Number Portability Act (RA 11202): Not about roaming pricing per se, but reinforces transparency and non-discrimination in mobile services.
Data Privacy Act (RA 10173): Telcos must process your location/usage data lawfully and with adequate notice, relevant when roaming is auto-activated or data is shared to partners.
Civil Code & remedial rules:
- Contract & quasi-delict remedies (refunds, damages, interest).
- Small Claims procedure (no lawyers required in hearings) for modest sums (as of 2024, the threshold was ₱1,000,000—verify current limit before filing).
Regulators:
- NTC (National Telecommunications Commission): Primary for telecom billing/service complaints; can order refunds/adjustments and sanction carriers.
- DTI: Handles unfair trade/deceptive advertising angles when applicable.
- BSP & card network rules: Path for chargebacks on credit-card-billed roaming if the charge is unauthorized or not rendered as described.

Practical takeaway: Start with the telco’s dispute desk; escalate to NTC for telecom-specific billing errors; consider DTI if the core problem is misleading marketing; use Small Claims for money recovery if needed.

3) Your core rights (what you can insist on)

Right to accurate and timely billing
- Bills must reflect actual usage, correct rate plans/add-ons, and accurate currency conversions.
- You can request an itemized breakdown (voice/SMS/data, volumes, timestamps, visited network/operator).
Right to clear disclosure
- Before (and while) roaming, you’re entitled to plain-language pricing: standard rates, bundle rates, inclusions/exclusions (e.g., VoLTE, hotspot), validity, zones, throttling, and out-of-bundle consequences.
- Welcome/roaming advisories should state rates or where to view them and how to opt out.
Right to opt-in/opt-out controls
- You can require roaming/data-roaming to remain OFF unless you activate it (and to permanently block if you never use it).
- You can demand spend caps (alerts at defined thresholds) and auto-bar once a limit is hit.
Right to remedies for erroneous charges
- Reversal/credit/refund for amounts not properly authorized or billed.
- Goodwill adjustments where the carrier’s process/messaging caused foreseeable “bill shock.”
- Interest and damages under civil law if you had quantifiable loss (e.g., card finance charges).
Right to data protection & minimal data processing
- Telcos should not silently activate roaming without lawful basis/notice.
- You may require deletion or restriction of unnecessary location logs beyond statutory retention.

4) What counts as an erroneous roaming charge?

Roaming billed when data/roaming switch was OFF on both device and carrier profile.
Charges outside the published bundle terms (e.g., billed per-MB inside the covered country).
Duplicate/overlapping CDRs, or usage posted to the wrong billing cycle.
Border roaming without adequate cell broadcast/notification and reasonable mitigation by the carrier when they know the area routinely mis-registers foreign towers.
Misleading offer (e.g., “₱X/day unlimited” with buried 100 MB cap triggering out-of-bundle).
No consent for activation or missing disclosures that would affect a reasonable user’s decision.

5) The playbook: from first dispute to full escalation

Step A — Lock down usage and gather proof (same day you notice)

Screenshots: Device settings (roaming toggles), carrier app showing active bundles, welcome SMS, rate texts, data usage graphs, and the bill page.
Timeline: Where you were (GPS logs, boarding passes), when alerts arrived, when a spend-cap SMS (if any) triggered.
Request from telco:
- Full itemized CDR (timestamps with time zone, visited network/operator name/MCC-MNC).
- Applied plan logic (which bundle, when activated/expired, rating engine notes).
- Copies of advisories sent to your number.

Step B — File a written billing dispute with your telco (within the bill’s dispute window)

Use the carrier’s official dispute channel (email/web form).
Ask them to suspend collection on the questioned amount while under investigation.
Demand a written resolution and a time frame.
Keep your account current on undisputed charges to avoid suspension.

Sample dispute letter (telco):

Subject: Billing Dispute – Erroneous International Roaming Charges for [Mobile No.]

I dispute ₱[amount] in roaming charges on my [bill date/cycle]. I did not authorize these charges and/or they were misrated.

Facts: [date/time], I was [location], received [welcome SMS/no SMS]. Device roaming/data switches were [off/on]. I had [name of roaming add-on] valid until [date]. See attached screenshots.

Requests:
1) Provide itemized CDRs with timestamps (including time zone), visited network, volumes.
2) Explain rating/bundle application and the legal basis for billing these charges.
3) Reverse/credit the erroneous amount and any finance charges.

Please treat this as a formal dispute and respond in writing within [reasonable period, e.g., 10 business days].

Step C — Escalate to the NTC if unresolved or denied unreasonably

File at the NTC Regional Office with: your dispute letter, carrier response (or non-response), proof of payments, contract/plan summary, and your evidence pack.
Ask for mediation (often fastest) or adjudication.
Relief sought: refund/credit, correction of records, waiver of penalties, and compliance order (e.g., spend caps, notifications).

Step D — Consider DTI if the crux is deceptive marketing

Example: “Unlimited” roaming where material throttling/out-of-bundle wasn’t disclosed in a clear, prominent way.

Step E — Small Claims Court (money back with interest)

Use if you want a judgment for refund/charges/penalties. Check the current small-claims cap (as of 2024 it was ₱1,000,000).
Sue the telco entity (proper corporate name); attach your dossier.
Claims: Sum of money, legal interest, and allowable costs. (No injunctive relief; for that, go to regular courts.)

Step F — Card chargeback (parallel track, if you paid via credit card)

File promptly with your issuing bank citing transaction not as described/unauthorized; attach your telco dispute and evidence.
Ask the bank to freeze finance charges on the contested amount.

6) Special cases

Border & maritime roaming (still in PH)

Ask the telco for a border-roaming whitelist (manual network selection to PH carriers).
Request free SMS alerts when your SIM first registers on a foreign network and at spend thresholds (e.g., ₱500/₱1,000/₱1,500).
If you can prove you remained in PH territory, press for full reversal on equity grounds.

Corporate-liable lines

Disputes typically must be filed by the authorized corporate contact; coordinate fast to meet cutoffs.
Check if your company’s Master Service Agreement includes bill-shock caps or SLAs—invoke them.

Prepaid users

You can still complain to NTC about misrating or misleading offers. Relief is usually recredit of load/Wallet.

Children/Family plans

Ask for IMEI-level or line-level roaming blocks and spend caps.
Use device profiles (iOS/Android) to hard-disable data roaming and background refresh.

eSIM & dual-SIM phones

Keep non-roaming SIM data-preferred; turn the roaming SIM’s data off unless needed.
Disable Wi-Fi Assist/Adaptive Connectivity which may flip to cellular during weak Wi-Fi abroad.

7) Evidence checklist (what wins cases)

Roaming/data toggles status (device & carrier app) with timestamps.
Screenshots of active bundles, validity, inclusions.
Welcome/Rate SMS, spend-cap alerts, or absence thereof.
Phone’s per-app data logs (Settings → Mobile Data → usage by app).
Location proofs: boarding passes, passport stamps, GPS history.
Billing documents: statement pages, ledger entries, and payment receipts.
Communications with the telco: ticket numbers, emails, chat transcripts.

8) Remedies you can ask for (and how to frame them)

Full reversal for charges incurred with roaming/data off, or when bundle terms were met.
Partial adjustment where the telco’s disclosure was unclear but you consumed some roaming.
Goodwill credit (bill-shock prevention failure, missed threshold alerts).
Waiver of late fees/finance charges on the disputed portion.
Prospective compliance: permanent roaming block, mandatory rate SMS, hard spend cap, or a “no-out-of-bundle” lock.

9) Preventive settings before you travel (or if you live in border areas)

Ask your telco to block international roaming by default (and require explicit opt-in).
If you need it, buy a roaming bundle in the app before departure and keep proof.
In device settings:
- Set Network Selection → Manual to your PH carrier while near borders.
- Turn Data Roaming OFF, disable Background App Refresh, Wi-Fi Assist, and automatic updates.
- Use Low Data Mode/Data Saver.
Prefer Wi-Fi calling or app-based calls on Wi-Fi (airline mode + Wi-Fi).
Consider a local eSIM at your destination or a travel eSIM with flat pricing.

10) FAQs

Q: The telco says “the foreign carrier billed us; nothing we can do.” A: The contract is between you and the PH telco. They chose the roaming partners and rating rules; they must bill you correctly and stand behind their product.

Q: Can they disconnect me while the dispute is pending? A: They shouldn’t cut service for undisputed amounts if you are current; ask them to suspend collection on the disputed portion and document this request.

Q: Do I need a lawyer? A: Not for Small Claims hearings. For complex or high-value disputes (or if you seek damages beyond refunds), consult counsel.

Q: How long do I have to file? A: Contract actions generally have longer prescriptive periods under the Civil Code, but internal dispute windows and card chargeback deadlines can be short. File as soon as you notice the error.

11) Ready-to-use templates

NTC complaint affidavit – key points to cover

Your full name, address, ID; mobile no., account no.
Facts in chronological order (dates, places, device settings, bundle details).
Copies of evidence (numbered annexes).
Prayer: refund/credit ₱__, correction of records, waiver of penalties, compliance orders, and other just relief.

Demand for goodwill & compliance (brief) “Given the unclear advisory/missed spend alerts, please apply a goodwill credit and enable a hard spend cap of ₱___ so future out-of-bundle use cannot occur.”

12) One-page strategy (keep this handy)

Freeze the bleeding: turn off data & roaming; set manual network selection.
Collect proof the same day.
File the telco dispute in writing; keep undisputed balances current.
Escalate to NTC with your evidence if not resolved.
Small Claims for refund + interest if needed; chargeback path if card-billed.
Prevent recurrence: enable permanent blocks, spend caps, and bundle-only roaming.

Final notes

Keep everything in writing.
Ask specifically for itemized CDRs and rating logic—that’s where many errors show.
When close to borders or at sea, treat your phone as if it’s abroad unless you’ve locked it down.

If you want, I can turn this into a printable checklist packet (with editable letter templates) tailored to your carrier and plan details.