This article explains Philippine rules that commonly apply when borrowers are harassed by collectors from online lending apps (OLAs). It is general information, not legal advice for your specific case.

1) The legal landscape (who regulates what)

Financial Consumer Protection Act of 2022 (R.A. 11765). Establishes your core rights as a financial consumer (fair treatment, truthful disclosure, data protection, redress). Gives regulators power to sanction abusive collection and misleading practices by financial service providers and their third-party collectors.
Lending Company Regulation Act (R.A. 9474) & Financing Company Act (R.A. 8556). Lending/financing companies must be registered and comply with the Securities and Exchange Commission (SEC) rules—including those addressing unfair collection practices and online lending platforms.
Bangko Sentral ng Pilipinas (BSP) rules. Apply if the lender is a bank, e-money issuer, or other BSP-supervised institution (BSFI). Consumer-protection and conduct standards cover outsourcing to collection agents.
Data Privacy Act of 2012 (R.A. 10173). Prohibits unauthorized processing, unnecessary or excessive collection, and unlawful disclosure of your personal data. “Contact scraping” and “shaming” (texting your phonebook, posting your information) can breach this law.
Cybercrime Prevention Act (R.A. 10175) & Revised Penal Code. Criminal liability can arise for libel/cyber-libel, grave/light threats, unjust vexation, intriguing against honor, coercion, and stalking/harassment depending on conduct and intent.
Anti-Wiretapping Act (R.A. 4200). Generally prohibits recording private communications without consent of all parties. Be careful when gathering audio evidence.

2) What counts as harassment or unlawful collection conduct

While the Philippines has no single “FDCPA-style” statute, abusive behaviors can violate multiple laws and regulations. Typical red flags include:

Shaming/doxxing: Messaging your employer, family, or phonebook contacts; posting your photo or debt online; creating group chats to expose you.
Threats & intimidation: Threats of arrest/jail (non-payment of debt is not a crime), violence, or public humiliation; threats to seize property without court order.
Deception & misrepresentation: Posing as lawyers, court officers, police, or “sheriffs”; sending fake “warrants,” “subpoenas,” or “case numbers.”
Excessive or odd-hour contacts: Repeated calls/messages at unreasonable hours or using multiple numbers to evade blocks.
Use of slurs or profanities; sexual harassment.
Data privacy breaches: Collecting unnecessary permissions (contacts, photos), retaining data longer than necessary, or disclosing to third parties without basis.
Unfair charges: Inflating interest, penalties, or “processing fees” beyond what was disclosed/agreed or beyond regulatory caps (when applicable).

3) Your core rights as a borrower

Right to fair, respectful treatment. Collectors must not harass, threaten, or humiliate you—directly or indirectly via your contacts.
Right to truthful, transparent information. You are entitled to clear disclosure of your loan’s principal, interest, fees, repayment schedule, total cost of credit, and basis for any collection demands.
Right to data privacy & minimal data processing. Apps must collect only data necessary for your loan and use it only for lawful, disclosed purposes. “Phonebook scraping” and mass messaging of your contacts are typically unlawful.
Right to redress. You can complain to the lender, then to the proper regulator (SEC or BSP), and seek administrative sanctions, restitution, or civil/criminal remedies.

4) Immediate steps if you’re being harassed

Preserve evidence (safely):
- Screenshot messages, caller IDs, chat profiles, app screens (include timestamps).
- Save payment records, loan agreements, disclosure screens, app permission prompts.
- Keep a log (date/time, number used, what was said).
- Do not make secret audio recordings without consent (R.A. 4200 risk).
Lock down your data:
- Revoke app permissions (contacts, storage, camera, mic, location).
- Change passwords/enable 2FA on email and social accounts.
- Consider uninstalling the app—but first ensure you’ve saved all needed evidence and have a copy of your agreement and statements.
Demand they stop harassing:
- Send a short cease-and-desist message to the lender and the numbers used by the collector. Request written communications via a single channel (email/SMS).
- If an agency is involved, demand the lender identify its authorized collector and provide the agency’s license/authority.
Clarify your account status:
- Ask for an updated statement of account: principal, interest, penalties, fees; payment history; and the legal basis for any add-ons.
- Propose a realistic payment plan if you intend to settle—prefer written confirmation of any restructure/waiver.

5) Where and how to complain

Identify the correct forum(s)—you can use more than one:

SEC (for lending/financing companies). File a complaint with screenshots, agreement, and your narrative. The SEC can investigate OLAs, order takedowns, suspend/revoke licenses, and penalize unfair collection practices.
BSP (for banks/EMIs/BSFIs). If your lender is bank-supervised, escalate through the bank’s consumer assistance first, then to BSP Consumer Assistance Mechanism (CAM).
National Privacy Commission (NPC). For data privacy abuses (contact scraping, doxxing, excessive permissions, unlawful disclosure). The NPC can order cease-and-desist, require data deletion, and impose penalties.
NBI-CCD / PNP-ACG. For criminal acts (grave threats, cyber-libel, extortion, identity theft). File an incident report and submit your evidence.
Barangay (Katarungang Pambarangay). If both parties are in the same city/municipality, barangay conciliation may be a precondition to certain civil suits (check exemptions).
Courts:
- Civil damages under Civil Code Articles 19, 20, 21 (abuse of rights/acts contrary to law/morals). You may claim actual, moral, exemplary damages and attorney’s fees.
- Injunction to restrain ongoing harassment or unlawful disclosures.
- Criminal complaints (via prosecutor) for threats, coercion, libel/cyber-libel, etc.

Tip: In your narrative, connect each abusive act to a legal basis (e.g., “Collector messaged my mother about my debt → unlawful disclosure of personal data; caused mental anguish → moral damages.”)

6) Drafting a cease-and-desist (CDD) letter: a simple template

Subject: Cease and Desist from Harassing/Unlawful Collection and Data Privacy Breaches To: [Lender/Collector name], [Email/Address]

I am the borrower under Loan No. [___].
Since [date], your agents have engaged in the following: [brief bullet list with dates/screenshots references].
These acts constitute unlawful collection and privacy violations under R.A. 11765, R.A. 10173, and the Revised Penal Code.
I demand that you:
- (a) stop all harassment and third-party contacts;
- (b) communicate only via [email/number], 9:00–6:00 PM;
- (c) provide within 5 business days a full statement of account and copies of my signed disclosures/consents;
- (d) delete personal data not necessary for my loan and confirm in writing.
Non-compliance will be reported to [SEC/BSP/NPC/NBI/PNP] and pursued in court.

Signed: [Name, Address, ID, Date]

Send via email and (if possible) registered mail; keep proof of transmittal.

7) Common defenses to abusive threats

“We will have you arrested.” False. Non-payment of a civil loan is not a criminal offense. Arrest requires a lawful warrant or in-flagrante criteria—not a collector’s say-so.
“We will garnish your salary tomorrow.” Not without final judgment and proper court processes (e.g., writ of execution/garnishment).
“We’ll contact your employer/friends because you consented.” Consent must be informed, specific, and time-bound under the Data Privacy Act. Blanket or hidden “phonebook access” is usually invalid for public shaming.
“We’re filing a case now; pay litigation fees.” Court fees are paid to the court, not to collectors via e-wallet links.

8) Practical settlement strategies (if you intend to pay)

Ask for a payoff computation separating principal, interest, penalties, and fees; challenge junk fees.
Negotiate waivers of penalties or “discounts” for lump-sum payment; get a written quitclaim/release and certificate of full payment.
Use traceable channels (bank transfer/e-wallet to official accounts). Save receipts.
Do not surrender your original IDs or ATM cards; never share OTPs.
Restructuring: If offered, insist on a written new schedule and a screen/letter confirming old penalties are waived/absorbed.

9) Evidence checklist (what to gather)

Loan application screens, KYC pages, permission prompts, e-mails, in-app terms, final disclosures.
Statement of account and payment history.
Screenshots of harassment, group chats, messages to contacts, caller lists with timestamps.
Names/numbers/handles of collectors; any proof they act for the lender.
Impact evidence: medical consults for anxiety, HR memos, affidavits of family/employer.
Delivery receipts for your CDD letter and complaints.

10) If the app accessed your contacts/photos

Revoke permissions in your phone settings; uninstall after exporting evidence.
Notify affected contacts briefly: “If you receive messages about me from [App], please ignore and forward to me.”
File with the NPC citing unlawful disclosure/incompatible purpose; request cease-and-desist and erasure of unlawfully obtained data.
Consider civil damages for invasion of privacy and criminal complaints if threats/defamation occurred.

11) Time limits, venue, and costs (high-level pointers)

Criminal offenses and civil claims have prescriptive periods (deadlines) that vary. Some (e.g., libel) can be short. Act promptly.
Venue typically lies where you or the defendant resides or where the wrongful act occurred; special rules apply for cyber-offenses and privacy cases.
Small Claims may provide a faster civil route for certain money claims, but harassment-based damages sometimes require regular civil actions. Ask counsel which track fits your facts and amount.

12) Choosing counsel (or when to go pro se)

Look for counsel with consumer protection, privacy, or fintech experience.
For modest claims, you may file certain complaints pro se (without a lawyer) at the SEC/BSP/NPC or through barangay conciliation; legal assistance can still help you frame issues and evidence.

13) Preventive tips before borrowing again

Verify the lender: registered with SEC (for OLAs) or supervised by BSP (for banks/EMIs).
Read APR/total cost and late-fee policies; avoid apps demanding contact access or gallery access.
Keep emergency buffers; borrow only what you can repay; prefer lenders that do not require phonebook access to operate.

14) Quick decision tree

Are you in danger? If yes (physical threats, stalking), go to PNP/NBI immediately.
Is the lender SEC-registered or BSP-supervised? File with the correct regulator (you can file with NPC in parallel for privacy issues).
Send a cease-and-desist, then escalate with your evidence packet.
Consider settlement (with documented waivers) or pursue civil/criminal remedies if harm was significant.

15) One-page action plan (copy/paste)

Gather screenshots, SOA, app permissions → put in dated folders.
Revoke app permissions; change passwords; notify close contacts.
Send CDD letter; channel communications to one address/number.
File complaints: SEC/BSP (conduct), NPC (privacy), NBI/PNP (criminal).
Negotiate payoff/restructure only in writing; pay via official channels.
Seek legal advice for damages/injunction if harassment continues.

Final note

You do not lose your legal protections just because you owe money. Abusive collection, shaming, and doxxing are punishable under multiple Philippine laws. If you’d like, tell me your exact situation (what was said, who was contacted, what permissions the app had), and I can help draft tailored complaint letters and a clean evidence outline.