Online scams in the Philippines are commonly pursued through a criminal complaint supported by a Complaint-Affidavit (also called an “Affidavit-Complaint”). This document is the backbone of your case at the Office of the City/Provincial Prosecutor (for preliminary investigation) and is also useful when reporting to the PNP Anti-Cybercrime Group (ACG) or the NBI Cybercrime Division for investigative assistance.

A well-drafted Complaint-Affidavit does three things:

Tells a clear, chronological story of what happened.
Connects the facts to the legal elements of the offense(s).
Authenticates and organizes evidence, especially electronic evidence.

1) What a Complaint-Affidavit is (and what it is not)

What it is

A sworn statement of facts (based on personal knowledge) alleging that a respondent committed a crime, supported by attachments (screenshots, payment proofs, transaction records, IDs, delivery records, etc.). It is typically filed to commence preliminary investigation under the criminal procedure framework.

What it is not

Not a social media “call-out” or public accusation.
Not a police blotter entry (a blotter is a record; it is not the prosecutor’s complaint).
Not merely a narrative: it must be sworn and supported by evidence.

2) Common criminal angles for “online scam” cases (Philippine context)

Many “online scam” fact patterns fit one or more of these:

A) Estafa (Swindling) — Revised Penal Code, Article 315 (commonly used)

Typical pattern: seller/buyer fraud, fake listings, bogus investment, downpayment taken then ghosted, “reserved item” scam, “agent fee” scam.

Key idea: deceit (false pretenses) used to induce you to part with money/property, causing damage.

B) Other Deceits — Revised Penal Code, Article 318 (sometimes used)

For deceitful acts that may not squarely fall under classic estafa modes but still involve fraudulent misrepresentation.

C) Cybercrime-related overlay — RA 10175 (Cybercrime Prevention Act)

Online scams often involve:

Computer-related fraud (conceptually), or
A traditional offense (like estafa) committed “through and with the use of” ICT—often treated as a cybercrime-related case in practice.

Practical point: Prosecutors frequently frame online scams as Estafa under the Revised Penal Code, with the cyber aspect strengthening the context and potentially affecting penalty treatment and court assignment (cybercrime courts/designated branches).

D) Identity-related and access-related acts (case-dependent)

If the scam involved impersonation, hacked accounts, phishing, OTP theft, unauthorized access or transfers, there may be additional charges (e.g., identity theft/illegal access concepts under cybercrime law, plus other special laws depending on the facts).

Drafting tip: In a Complaint-Affidavit, you don’t need to “perfectly” label the crime on your own. What matters is that your facts establish the elements; you can state “for Estafa and/or other applicable offenses” and let the prosecutor determine the proper charge.

3) Before drafting: evidence gathering and preservation (especially electronic evidence)

Online scam cases succeed or fail on evidence. Preserve both content and context.

A) Minimum evidence checklist (typical online marketplace/investment scam)

Identity/handles

Screenshots of the respondent’s profile, username/handle, display name
Any posted ads/listings/stories, group posts, comments, timestamps
Phone numbers, email addresses, links, QR codes, wallet IDs, bank details

Communications

Screenshots (or exports) of chat messages showing:
- offer/representation (price, item, promise, ROI, timeline)
- your acceptance/reliance
- instructions to pay/transfer
- proof they received payment or acknowledged
- follow-ups and their evasions/ghosting

Payment trail

Bank transfer receipt, InstaPay/PesoNet reference, deposit slip
E-wallet transfer receipt (GCash/Maya, etc.) with reference numbers
Screenshot showing the recipient name/number/account
Your bank statement page reflecting the transfer (if available)

Delivery/non-delivery

If goods: shipping waybill (or the absence of one), promised tracking number, delivery confirmations
If services/investments: promised payout schedule vs. missed dates, repeated excuses

Loss/damage computation

Exact amount paid
Additional costs (shipping, “processing fee,” “insurance,” “release fee,” etc.)
If partial refund happened, document that and compute net loss

B) Preserve “metadata” and reliability signals

Courts and prosecutors care about whether screenshots are trustworthy. Improve credibility by documenting:

Date/time on device when screenshot taken
URL or platform (Facebook Marketplace, Instagram, Telegram, Viber, WhatsApp, email, website)
Message timestamps visible
Full conversation context (avoid cropped screenshots that remove sequence)
If possible: screen recording while scrolling the conversation, showing the account/profile page

C) Avoid evidence pitfalls

Don’t edit images (no markup that changes content). If you must highlight, keep a clean original copy too.
Don’t delete chats; archive/export if the platform allows.
Don’t rely on hearsay (“my friend said…”). If a friend interacted with the scammer, your friend should execute a separate affidavit.

4) Where the Complaint-Affidavit is filed (and why that matters to drafting)

A) Office of the Prosecutor (City/Provincial)

If you want a criminal case filed in court, your Complaint-Affidavit is normally for the prosecutor’s preliminary investigation (or in some limited cases, inquest-related situations—less typical for scams).

Result: If probable cause is found, an Information is filed in court.

B) PNP ACG / NBI Cybercrime Division

They can assist in investigation (tracing, requests, coordination), but criminal charging commonly still routes through the prosecutor. Your affidavit is still useful here.

C) Venue and jurisdiction basics (practical)

Cyber/online transactions blur geography. In drafting, state clearly:

Where you were when you received the misrepresentation and sent payment
Where your bank/e-wallet account is maintained (if relevant)
Any known location of respondent (if known)

This helps establish that your prosecutor’s office can take cognizance of the complaint.

5) Structure of a strong Complaint-Affidavit (Philippine format)

A Complaint-Affidavit usually has:

Caption / heading
Personal circumstances of affiant
Statement of facts (chronological; numbered paragraphs)
Legal anchoring (brief; connect facts to elements)
Evidence list / Annexes
Prayer
Verification / Oath (Jurat) with signature

A) Caption (common style)

Use a formal caption similar to pleadings:

Republic of the Philippines
Office of the City Prosecutor / Provincial Prosecutor
City/Province

Then a case-style title:

IN RE: COMPLAINT FOR ESTFA AND/OR OTHER APPLICABLE OFFENSES Complainant: (Your Name) Respondent/s: (Name/Unknown person using account “”, phone “”, bank/e-wallet “_____”)

Some offices prefer: “PEOPLE OF THE PHILIPPINES vs. [Respondent]” at later stages; at prosecutor level, “IN RE” is common.

B) Affiant’s personal circumstances

Include:

Full name
Age
Citizenship
Civil status (optional but common)
Address
Occupation (optional)
Government ID presented (type and number) (often stated during notarization; can also be in affidavit)

C) Statement of facts (best practices)

Write in numbered paragraphs. Keep it:

Chronological
Specific (dates, times, amounts, account numbers, reference numbers)
Factual (avoid conclusions like “clearly a scam” unless supported)
First-hand (what you personally saw, did, received)

Use a timeline approach:

How you found the respondent/listing
What was represented/promised
What you agreed to and why you believed it
Payment instructions given
Payment made (how, when, amount, reference)
What happened after (non-delivery, excuses, ghosting, threats)
Your demand/refund attempts
Resulting damage/loss

D) Legal anchoring (short but targeted)

After the facts, add a section like:

“The foregoing acts constitute Estafa because…” Then link your facts to:
misrepresentation/false pretenses
reliance
payment/transfer
damage

Keep it concise; let the facts do the heavy lifting.

E) Annexes

Label every attachment and refer to it in the body:

“Attached as Annex ‘A’ is a screenshot of the listing…”
“Annex ‘B’ is the chat conversation…”
“Annex ‘C’ is the proof of payment…”

Make an Annex Index.

6) Drafting details that often decide outcomes

A) Identify the respondent even if you don’t know the real name

Online scammers hide behind accounts. You can still file against:

“JOHN DOE / UNKNOWN PERSON using Facebook account ‘____’” Add identifiers:
profile link
username/handle
phone number used
bank/e-wallet account details
delivery rider details (if any)
any ID they sent (even if fake—attach it)

B) Write down exact representations (quote them)

Instead of “He promised delivery,” write:

“Respondent stated: ‘I will ship today and send the tracking number tonight.’ (Annex ‘B’)”

Direct quotes tied to annexes are persuasive.

C) Show reliance and inducement

Prosecutors look for: you paid because you believed the representation. Include your decision point:

“Relying on respondent’s assurance that the item was on-hand and ready to ship, I transferred ₱____.”

D) Show demand/refusal or evasion

For many scam patterns, document that you attempted to resolve and that the respondent:

blocked you
stopped replying
kept moving deadlines
demanded more fees

E) Damage computation

State:

Total paid (with breakdown)
Less any refunds
Net loss

F) Multiple victims (pattern evidence)

If you discovered other victims, don’t rely on rumors. If they are willing, they should execute their own affidavits. You may attach:

public posts from victims (with caution), and/or
coordinate for separate sworn statements

7) Template: Complaint-Affidavit (customizable Philippine-style)

Below is a practical template. Adjust to your facts and the filing office’s preferences.

REPUBLIC OF THE PHILIPPINES ) CITY/PROVINCE OF ________ ) S.S.

COMPLAINT-AFFIDAVIT

I, [Full Name], of legal age, Filipino, [civil status], and residing at [address], after having been duly sworn in accordance with law, hereby depose and state:

Personal circumstances. I am the complainant in this case. I can competently testify to the facts stated herein based on my personal knowledge and on authentic records in my possession.
Identity of respondent. This complaint is filed against [Respondent’s full name, if known], and/or JOHN DOE / UNKNOWN PERSON using [platform/account name/handle], reachable through [mobile number/email], who instructed me to send money to [bank/e-wallet name] account [number] under the name [recipient name as shown] (collectively, “Respondent”).
How I came into contact with respondent. On [date], I saw [a post/listing/advertisement/message] on [platform/group/page] offering [item/service/investment] for ₱[amount]. A copy/screenshot of the listing/profile is attached as Annex “A.”
Respondent’s representations. Respondent represented to me that [specific representations: item is available, original, ready to ship; investment guaranteed; job offer legitimate; etc.]. In our conversation on [date/s], respondent specifically stated, among others, “[quote]” and “[quote]”. Screenshots of our communications are attached as Annex “B.”
My reliance and agreement. Relying on respondent’s representations and assurances, I agreed to [buy/invest/pay reservation] and to transfer the amount of ₱[amount] on [date].
Payment made. On [date/time], I transferred ₱[amount] via [bank/e-wallet] to [recipient details] with reference/transaction number [ref no.]. Proof of payment and/or relevant account records are attached as Annex “C.”
Non-delivery / failure to perform. After receiving my payment, respondent [failed to deliver the item / failed to provide the service / failed to release promised returns]. Respondent then [gave excuses / demanded additional fees / became unreachable / blocked me] beginning [date]. Screenshots of these subsequent messages (or evidence of being blocked) are attached as Annex “D.”
Demand. On [date], I demanded that respondent [deliver the item / return my money]. Despite repeated follow-ups, respondent [refused/failed/ignored]. Copies of my demand messages and respondent’s replies (or lack thereof) are attached as Annex “E.”
Damage. As a result of respondent’s acts, I suffered damage in the amount of ₱[net amount], representing [breakdown: principal amount + fees], less ₱[refund if any].
Criminality of acts. Respondent employed false pretenses and fraudulent representations to induce me to part with my money, and thereafter failed to deliver or return the amount, causing me damage. Respondent’s acts constitute Estafa and/or other applicable offenses, considering the manner the deception was carried out through online communications and electronic platforms.
Prayer. I respectfully pray that, after due proceedings, respondent be required to answer this complaint, and that the appropriate criminal Information be filed in court against respondent, together with all other reliefs just and equitable.

IN WITNESS WHEREOF, I have hereunto set my hand this [date] at [city], Philippines.

[Signature over printed name] [Full Name] Complainant-Affiant

SUBSCRIBED AND SWORN to before me this [date] at [city], Philippines, affiant exhibiting to me [ID type and number].

[Notary Public / Administering Officer] Doc No. ____; Page No. ____; Book No. ____; Series of ____.

Notes on the template

Some prosecutor offices prefer the oath administered by their office rather than notarization; others accept notarized affidavits. If in doubt, notarization is commonly acceptable for filing, subject to local office rules.
Keep the “Criminality of acts” section short; avoid over-arguing.

8) Annex preparation: make your attachments prosecution-ready

A) Annex Index (sample)

Annex “A” – Screenshot of listing and respondent’s profile page
Annex “B” – Screenshots of chat showing offer, agreement, payment instructions
Annex “C” – Proof of payment / bank transfer receipt / e-wallet receipt
Annex “D” – Screenshots showing non-delivery, excuses, blocking
Annex “E” – Demand messages and follow-ups
Annex “F” – Bank statement page showing debit (if available)
Annex “G” – Other corroborating records (delivery app logs, email headers, etc.)

B) Practical formatting tips

Put annexes in chronological order.
On each printed annex page, write: “Annex ‘__’”, and initial/sign if feasible.
Ensure timestamps/usernames are visible.
Don’t submit a “wall” of screenshots with no explanation—reference each annex in your numbered facts.

9) Filing flow after you finish the affidavit (what your draft should anticipate)

A typical prosecutor process:

Filing of complaint, affidavits, and annexes
Subpoena to respondent (if identifiable/reachable) to submit a Counter-Affidavit
Reply-Affidavit (optional, depending on office practice)
Resolution: probable cause or dismissal
If probable cause: filing of Information in court

Drafting implication: Your Complaint-Affidavit must be complete enough to stand even if the respondent never appears, and structured so the prosecutor can easily map facts to elements.

10) Common mistakes that get online scam complaints dismissed or weakened

No proof of payment (or unclear recipient details).
Screenshots with no identifiers (no username, no timestamps, cropped context).
Pure conclusions (“He scammed me”) without quoting the false representations.
Missing reliance (not explaining why you believed and paid).
Unclear amount of loss (no computation; inconsistent figures).
Filing against a name with no link to the scam (wrong person), while omitting the actual account/number used.
Hearsay-heavy narrative without affidavits from witnesses.
Evidence altered (edited screenshots) without preserving originals.
Messy timeline (facts jumping back and forth, making intent hard to infer).
Demand section omitted in patterns where it helps show refusal/evasion.

11) Advanced drafting points for special scam patterns

A) “Additional fee” / “release” / “insurance” scam

Show the incremental deceit:

initial “low price”
then “processing fee,” then “release fee,” etc. Attach each transfer as separate annex items and compute total loss.

B) Investment / “double your money” / guaranteed returns

Emphasize:

promises of return at specific dates
repeated postponements
use of fabricated “proofs” or fake dashboards Attach the promised schedule and missed deadlines.

C) Account takeover / OTP / unauthorized transfers

Document:

when you lost access
suspicious login alerts
OTP messages
bank notifications
immediate steps you took (hotline report, ticket number) These cases often require tighter technical chronology.

D) Multiple respondents (money mule accounts, intermediaries)

Name each respondent category:

the one you communicated with (account handle)
the one who received funds (bank/e-wallet holder name)
delivery rider/agent (if any) Even if you cannot prove conspiracy at the outset, documenting each role helps investigation.

12) Quick drafting checklist (one-page view)

Facts

Dates/times, platform, respondent identifiers
Exact representations quoted
Reliance: why you paid
Payment details: amount, method, ref no., recipient
Non-performance: non-delivery/ghosting/excuses
Demand and refusal/evasion
Net damage computation

Evidence

Listing/profile screenshots (Annex A)
Full chat sequence (Annex B)
Proof of payment + account details (Annex C)
Post-payment exchanges / blocked proof (Annex D)
Demand messages (Annex E)
Optional: bank statement, screen recording, emails

Form

Numbered paragraphs
Annex references inside narrative
Proper caption and respondent description
Sworn/subscribed (notarized or administered by proper officer)

Conclusion

Drafting a Complaint-Affidavit for an online scam in the Philippines is primarily about precision: a clean timeline, exact representations, a documented payment trail, and well-labeled electronic evidence. When those pieces are present and organized, the affidavit becomes both a persuasive narrative and a ready-to-use foundation for preliminary investigation and eventual prosecution.