Disputing Unauthorized Credit Card Transactions in the Philippines

A 2025 practitioner’s guide for consumers, banks, and lawyers

1. Snapshot

When a charge appears on your credit-card bill that you did not authorize, Philippine law gives you a clear, time-bound pathway to have it reversed and to protect your credit standing. The framework rests on three pillars:

Pillar	Key statute / rule	Core promise to consumers
Fraud & misuse are crimes	R.A. 8484 – Access Devices Regulation Act (1998)	Making or using an unauthorized card or card data is punishable by up to 20 years’ imprisonment plus heavy fines.
Cardholder liability is capped	R.A. 10870 – Philippine Credit Card Industry Regulation Act (2016) and its BSP Implementing Rules (2017)	Your personal liability stops at ₱2,000 for transactions made before you report the loss/fraud, and drops to ₱0 once you notify the issuer.
Rapid, orderly complaint handling	R.A. 11765 – Financial Products and Services Consumer Protection Act (2022) + BSP Consumer Protection Circulars (esp. Circ. 1154-2022 & 1160-2023)	Issuers must: ① accept disputes 24 / 7; ② give provisional credit within 10 banking days; ③ finish domestic investigations in ≤45 days (≤90 days if foreign); ④ freeze interest/penalties on the amount while the probe is open.

2. What counts as an “unauthorized” transaction?

Card-present fraud – stolen or counterfeit plastic used in stores/ATMs.
Card-not-present (CNP) fraud – online, phone, mail orders made with stolen credentials.
Account-takeover – criminal changes delivery address, mobile number, or e-mail to intercept OTP or statements.
Processing errors – merchant double-charges, charges the wrong amount, or repeats a voided sale.
Lost goods/services – you cancelled or never received what you paid for, and merchant refused a refund (Visa/MC Reason Code “Goods/Services not received”).

✅ Tip: Charges made by a supplementary card-holder are not “unauthorized” unless you can prove the supplementary card was itself lost, stolen, or mis-used after revocation.

3. Duties of the cardholder

Duty	Time limit	Legal basis
Safeguard the card & PIN/OTP	Continuous	R.A. 10870 §10(a)
Notify the issuer (phone, app, e-mail, branch) once you suspect loss/fraud	Immediately (best-effort)	R.A. 10870 §10(b)
File a formal dispute/affidavit (bank’s form + ID + proof)	Within 30 days of statement date (banks may allow 60 days)	BSP IRR §52
Assist the investigation (submit any extra evidence requested)	Within issuer’s deadline (usually 5–7 days)	BSP Consumer Protection Standards

Failure to meet these timelines can let the bank deny the chargeback.

4. Obligations of issuers & acquirers

24 / 7 reporting channels (hotline, e-mail, in-app chat).
Block & replace the compromised card immediately at no cost.
Provisional credit or manual reversal ≤10 banking days after receiving complete documents (R.A. 11765, BSP Circ. 1154).
No interest, finance charge, or late fee on the disputed amount while under review.
Written status updates every 20 days on request, final resolution ≤45 days for domestic, ≤90 days for cross-border.
If the bank rules against you, it must:
- give you at least 5 days’ written notice before re-debiting;
- reinstate interest/fees only from re-debit date, not retroactively;
- provide the retrieval/chargeback documentation that justified the denial.

5. The step-by-step dispute workflow

Detect – review e-mail alerts, SMS, push notifications, monthly e-statement.
Report – call the bank’s hotline, note the reference number and time.
Document – fill out the “Customer Dispute Form/Affidavit of Fraud,” attach a government ID, statement copy with the item circled, and any chat/e-mail proving you tried to resolve with the merchant (for service-related disputes).
Card blocking & reissue – bank cancels card, generates new PAN; SMS confirmation normally arrives within minutes.
Bank files a chargeback via Visa / Mastercard / JCB / AmEx network, citing the correct reason code.
Provisional credit appears on your account; interest on that item is frozen.
Investigation – issuer awaits acquirer/merchant response; may request more info from you (shipping proof, police report for lost card, etc.).
Outcome:
- Chargeback honoured → provisional credit becomes permanent.
- Chargeback rejected → issuer may represent and try a 2nd cycle, or pass cost to you with explanation.
Escalate if unhappy (see § 6).

6. Escalation & remedies

Level	Forum	What happens
1. Bank’s internal Consumer Assistance Group	E-mail / postal mail marked “SECOND LEVEL COMPLAINT”	Free; bank must answer in 15 BD.
2. Bangko Sentral ng Pilipinas (BSP) – CAMS portal	https://www.bsp.gov.ph › Consumers › File-a-Complaint	BSP mediates; average turnaround 30–60 days.
3. Department of Trade & Industry (DTI) – for merchant-side issues	Fair Trade Enforcement Bureau (e-commerce division)	Issues show-cause orders to merchant.
4. National Privacy Commission (data breach)	npc.gov.ph complaints desk	Orders data-security fixes; can impose fines.
5. Criminal action	NBI Cybercrime Division / local prosecutor	Prosecute under R.A. 8484, R.A. 10175 (Cybercrime), estafa.
6. Civil suit (collection or damages)	Regular trial courts	Recover actual & moral damages, plus attorney’s fees.

7. Special situations & frequently tested issues

Situation	How the rules apply
Contactless / NFC tap fraud	Still covered by R.A. 10870 liability cap. No OTP required for low-value taps, so issuer bears most network-imposed liability.
Tokenized cards in e-wallets (G-Cash, Maya, Apple Pay)	The issuing bank remains the party to dispute with. Wallets follow the same 10-day provisional-credit rule under BSP Circ. 1160-2023.
Supplementary cards	Principal cardholder is liable unless the supplementary card was reported lost before the transaction.
Merchant already refunded	Ask the merchant for the Acquirer Reference Number (ARN) to track in issuer’s system; bank must post the credit within 5 BD once visible in Visa/MC clearing.
Chargeback filed late by bank	If you met your 30-day duty but the issuer missed the network deadline, the bank eats the loss—consumer is held harmless (BSP IRR §53(d)).
Negative credit-bureau reporting during dispute	Prohibited. R.A. 10870 §9 bars adverse reporting on an amount officially under investigation.

8. Best practices to prevent future fraud

Enable real-time SMS/e-mail/app alerts for every transaction—most issuers are now free.
Turn on two-factor authentication and 3-D Secure (EMV 3-DS) for online purchases.
Keep a secure, separate e-mail for financial accounts; resist phishing links.
Use virtual card numbers or disposable e-commerce cards with low limits.
Review statements every week, not just at month-end.
When travelling, inform the bank via the app; set spending alerts so you spot rogue overseas charges fast.

9. Model dispute letter / e-mail

Subject: URGENT – Unauthorized credit-card charge dispute (Ref No. _______)

Dear [Issuer] Disputes Team,

I am writing under R.A. 10870 and R.A. 11765 to dispute the following transaction, which I did not authorize: Posting Date: 05 Jun 2025 Merchant: XYZ Digital HK Amount: ₱ 8,750.00 My card was in my possession at all times. I have enclosed the required Dispute Form, a copy of my valid ID, and screenshots of the SMS alert.

Kindly block the card, issue a replacement, and credit back the amount within the statutory ten-day period while you conduct your investigation. Please send written confirmation and the case reference number.

Thank you.

[Signature] Name / Card number (last 4) / Mobile / E-mail**

10. Key statutes & circulars (for further reading)

R.A. 8484 – Access Devices Regulation Act of 1998.
R.A. 10870 – Philippine Credit Card Industry Regulation Act + BSP IRR (BSP Circular No. 936-2017).
R.A. 11765 – Financial Products and Services Consumer Protection Act; BSP Circular Nos. 1154-2022 & 1160-2023.
BSP Circular No. 702-2006 – Consumer Protection Framework (still cross-referenced).
R.A. 10175 – Cybercrime Prevention Act of 2012.
Data Privacy Act (R.A. 10173) – for breaches of card data.

11. Frequently asked questions

Question	Short answer
Can the bank collect interest on the disputed amount during review?	No. Interest/fees are frozen once you lodge a compliant dispute.
What if I spot the charge after 30 days?	File anyway; banks may honour up to 60 days. Beyond that, odds drop sharply unless you prove late posting.
Will disputing hurt my credit score?	Properly filed disputes do not trigger negative reporting. Only confirmed delinquency does.
Do I need a police report?	Not for small CNP fraud. Banks may require it for physical card theft or high-value losses (>₱100 k).
How long before I get a new card?	Typically 3-5 BD Metro Manila (courier), 7-10 BD provincial. Emergency issuance inside 48h is free for fraud cases.

Disclaimer

This article is for general information as of 26 June 2025. It does not constitute formal legal advice. Always consult your bank’s actual card agreement and, for complex or high-value cases, seek counsel from a Philippine lawyer experienced in consumer-finance disputes.