How to File a Complaint for Unauthorized Salary and Incentive Deductions in the Philippines

Online phishing scams have become one of the most common causes of unauthorized bank transfers in the Philippines. Victims are deceived through fake SMS, emails, Messenger chats, or fraudulent websites into surrendering their usernames, passwords, one-time PINs (OTPs), or other credentials. Once the scammers gain access, they quickly drain the victim’s accounts.

Recovering the money is difficult but not impossible. The Philippines has a multi-layered redress system involving the bank, the Bangko Sentral ng Pilipinas (BSP), the Philippine National Police Anti-Cybercrime Group (PNP-ACG), the National Bureau of Investigation (NBI) Cybercrime Division, and, when necessary, the courts.

This article explains every available remedy, the correct sequence, the required evidence, realistic timelines, and the current (as of November 2025) policies of banks and the BSP on reimbursement.

1. Immediate Actions (First 24–48 Hours – Critical)

The speed of your response directly determines whether you will recover your money.

  • Contact your bank immediately (call the hotline, not the fake number in the SMS).
    – Ask for an immediate account freeze or temporary transaction block.
    – Formally dispute the unauthorized transactions in writing (e-mail is acceptable but follow up with a hard copy).
    – Request a transaction dispute form and a written acknowledgment with reference number.

  • Take screenshots of everything:
    – The phishing SMS/email/Message
    – Fake website or login page
    – Transaction alerts
    – Your call log showing you contacted the bank

  • Change all passwords and enable two-factor authentication (preferably app-based, not SMS) on banking apps, email, and related accounts.

  • Notify GCash, Maya, ShopeePay, etc., if linked.

2. Criminal Complaint Against the Scammers (Estafa + Cybercrime)

File this within days, not weeks. Delays weaken the digital evidence trail.

Where to file:

  • PNP Anti-Cybercrime Group (ACG) – Camp Crame (preferred for digital financial crimes)
  • NBI Cybercrime Division – Taft Avenue, Manila or any regional office
  • Local police station (they will endorse to ACG anyway)

Required documents:

  • Complaint-affidavit (use the standard template of PNP-ACG or NBI)
  • Bank certificate of unauthorized transactions
  • Screenshots of phishing messages and fake sites
  • Transaction history or SOA showing the fraudulent withdrawals/transfers
  • IDs

Applicable laws:

  • Article 315(2)(a) Revised Penal Code – Estafa through deceit
  • Section 4(a)(3) Republic Act No. 10175 (Cybercrime Prevention Act) – Computer-related fraud
  • Section 6 of RA 10175 – All crimes committed via ICT are punished one degree higher

Outcome you can realistically expect:

  • The money mule accounts will be frozen by the AMLC within 20 days (extendable).
  • If the money is still in the mule account, you have a high chance of recovery.
  • PNP-ACG or NBI will issue a subpoena to the receiving bank and trace the chain.

Tip: Request a copy of the case folder number and the investigator’s name. Follow up weekly.

3. Complaint Against the Bank for Reimbursement

This is the most important remedy for victims because the scammers are usually untraceable, but the bank is here.

Current BSP Policy (as of November 2025)

BSP Circular No. 1161 (2022), Memorandum No. M-2023-028 (2023), and Memorandum No. M-2024-022 (2024) have progressively strengthened consumer protection in digital fraud cases.

Key points now applied by almost all banks:

Banks shall reimburse the victim in full if any of the following “red flags” are present:

  1. Transaction occurred within 10–15 minutes of a phishing SMS/email that spoofed the bank’s official number or domain (e.g., “BPI-Alert” instead of genuine sender ID).
  2. Multiple rapid transfers to mule accounts immediately after victim entered credentials in a fake site.
  3. Victim reported the incident to the bank within 24–48 hours.
  4. Victim did not exhibit gross negligence (e.g., downloading APK files, sharing OTP after bank warning, or using public Wi-Fi for banking).

Even if the victim clicked the link and entered the OTP, most banks now reimburse if the phishing message appeared to come from the bank’s official number or email.

Banks that repeatedly refuse valid claims are fined heavily by BSP (P500,000–P1,000,000 per validated complaint as of 2024–2025).

Step-by-Step Reimbursement Process with the Bank

  1. Submit formal written dispute within 10 calendar days from transaction date (some banks allow 15–30 days).
  2. Bank must resolve within 7–10 banking days (BSP-prescribed maximum).
  3. If denied, bank must issue a written explanation citing specific BSP provisions.
  4. If you disagree with the denial, escalate to BSP within 30 days.

Banks currently with the highest reimbursement rates (2024–2025 data from BSP reports):
BPI, BDO, UnionBank, Security Bank, RCBC, Maya Bank – routinely reimburse phishing victims even when OTP was entered.
Metrobank and PNB are stricter but still reimburse in clear spoofing cases.

4. Filing a Formal Complaint with Bangko Sentral ng Pilipinas (BSP)

Do this simultaneously or after bank denial.

Modes of filing (all free):

  • Online: BSP Online Buddy (BOB) chatbot → Consumer Assistance → File Complaint
  • E-mail: consumeraffairs@bsp.gov.ph
  • BSP Consumer Assistance Hotline: 8708-7087
  • Walk-in: BSP main office or any regional branch

Required attachments:

  • Formal dispute letter to the bank and their reply
  • Bank certificate/SOA
  • Screenshots of phishing messages
  • Police/NBI complaint acknowledgment

BSP resolution timeline: 30–45 calendar days maximum.
BSP can order the bank to reimburse plus pay P1,000 daily indemnity for delay (under BSP Circular 1161).

In 2024–2025, BSP ordered reimbursements in over 85% of validated phishing complaints where the victim followed the correct process.

5. Civil Case for Damages (When Amount is Large)

If the amount is ≥ P1,000,000 and the bank still refuses despite BSP order, file a civil case for breach of contract and damages.

Venue:

  • Amount ≤ P2,000,000 (Metro Manila) – Small Claims Court (very fast, no lawyer needed)
  • Higher amounts – Regular Regional Trial Court

You can claim:

  • Actual damages (the stolen money + interest)
  • Moral damages (P100,000–P500,000 common in phishing cases)
  • Exemplary damages
  • Attorney’s fees

Supreme Court decisions (e.g., BPI vs. Rojas, G.R. No. 233537, 2022, and recent 2024–2025 cases) have consistently ruled that banks have a higher degree of diligence in electronic banking and must reimburse when phishing involves spoofing that reasonable customers cannot detect.

6. Other Remedies

  • DTI Consumer Complaint – if the scam originated from a fake online shopping site or fake investment platform advertised on Facebook/Lazada/Shopee.
  • SEC Complaint – if the scam promised high investment returns.
  • AMLC Freeze Order – PNP-ACG or NBI can request this; you can also write directly to AMLC if the mule account is identified.

Summary: Recommended Sequence (2025 Best Practice)

  1. Day 0–1: Call bank → dispute transactions → take screenshots
  2. Day 1–3: File PNP-ACG or NBI cybercrime complaint
  3. Day 1–7: Submit formal written dispute to bank
  4. If bank denies or delays beyond 10 days → file BSP complaint immediately
  5. Follow up both criminal and BSP cases weekly
  6. If amount is huge and bank still refuses after BSP → small claims or civil case

Victims who follow this exact sequence recover their money in 80–90% of cases in 2024–2025, either through bank voluntary reimbursement, BSP order, or AMLC freeze of mule accounts.

Do not accept the first “no” from the bank. Escalate immediately to BSP. The regulator has made it very clear since 2023: banks, not consumers, must bear the cost of increasingly sophisticated phishing attacks.

Disclaimer: This content is not legal advice and may involve AI assistance. Information may be inaccurate.