How to File a Complaint Against an Online-Game Scam in the Philippines
(Everything you need to know, in one place)
Scope & style note This article focuses on scams that arise in, around, or through online and mobile games—e-sport betting fraud, fake top-up sellers, hijacked or “rented” accounts, play-to-earn rug-pulls, gacha/loot-box manipulation, phishing pages that mimic publishers, crypto-based in-game tokens, and similar schemes. It is written for players, parents, guild owners, cyber-café operators, streamers, and indie developers who find themselves victim-oriented. It is not a substitute for personal legal advice; when in doubt, consult counsel.
1. Know the Common Legal Theories
| Possible Case | Usual Legal Basis | Key Elements to Prove | Maximum Penalty |
|---|---|---|---|
| Online Estafa / Swindling | Art. 315, Revised Penal Code (RPC) with Sec. 6, Cybercrime Prevention Act (RA 10175) | deceit, damage, element of fraud via computer system | Reclusion temporal + ₱200k–₱5M fine (graduated) |
| Access Device Fraud (e.g., stolen GCash, credit-card linked to the game) | Access Devices Regulation Act (RA 8484) | unauthorized use of card/device, intent to defraud | Up to 20 yrs + ₱10k per access |
| Unfair or Deceptive Sale of Digital Goods | Consumer Act (RA 7394) + DTI BPS rules | misrepresentation, hidden terms, defective virtual goods | Fine ₱1k–₱300k + closure |
| Unregistered Securities / P2E Tokens | Securities Regulation Code (RA 8799) | sale of investment contracts w/out SEC licence | ₱5M fine or 7 yrs jail |
| Data Privacy Breach (phished credentials) | Data Privacy Act (RA 10173) | unauthorized processing, damage to data subjects | ₱500k–₱5M + 3–6 yrs |
| Gambling w/out Permit (betting skins, esports) | PD 1602, EO 13 (2017), Pagcor charter | “game of chance” for money w/out authority | ₱12k–₱200k + 6 mos–6 yrs |
Why this matters: You do not have to decide which statute applies before complaining; agencies will re-tag the case. But knowing the menu helps you collect the right proof.
2. Gather Bullet-Proof Evidence (“If it’s not saved, it never happened.”)
- Screenshots / Screen-captures Full window, include URL bar and timestamp. Use “print window” in Steam/Epic/Google Play to show order IDs.
- Transaction Slips & E-wallet Logs • GCash/GrabPay/PayMaya PDFs, card statements, blockchain hash screenshots.
- Chat Logs & E-mail Trails • Export WhatsApp, Messenger, Discord DM as “.html” with headers.
- Game Logs / UID • Most titles have “game ID” in settings; take a photo.
- Identity Trail of the Scammer • Phone number (RA 11934 SIM-registration), payment name, IP (if publisher can give).
- Affidavit of Complaint • Draft a narrative, attach Annex “A” (evidence list). Notarize or do e-notary via Supreme Court’s 2021 guidelines.
Keep originals and three sets of photocopies or PDFs on cloud.
3. Decide Where to File (Multi-Door Approach)
| Agency / Office | When to Choose It | How to File | Typical Outcome |
|---|---|---|---|
| NBI Cybercrime Division | Large-value fraud, cross-border syndicate, need subpoenas | Walk-in (Manila Taft Ave ), or NBI e-Complaint portal | Formal investigation, request ISP data, inquest before DOJ |
| PNP-ACG (Anti-Cybercrime Group) | Perpetrator located in PH, need immediate arrest | Dial 0966-976-5971 (24/7) or go to regional ACG unit | Warrant application, hot-pursuit ops |
| DICT-CICC (#1326) | If unsure of jurisdiction; one-stop queueing system | Call or online form; they route to proper agency | Tracking number; referral |
| DTI Fair-Trade Enforcement Bureau | Consumer issues vs. Philippine-based seller/top-up shop | File online via DTI ConsumerCare; mediation | Refund / administrative fine |
| SEC Enforcement & Investor Protection Dept. | Token / P2E schemes that look like investments | E-mail complaints@sec.gov.ph | Cease & desist, asset freeze |
| BSP Complaints Management | Unauthorized e-money debits, chargebacks refused | Through your bank or BSP Online Buddy | Reversal, penalty vs EMI |
| Barangay Lupon (optional) | Small claims < ₱5k, both parties in same barangay; civil only | Ask for Punong Barangay mediation | Amicable settlement (Kasunduan) |
| Regular Prosecutor’s Office | If you have names/addresses; go criminal direct | File verified complaint-affidavit with annexes | Prosecutor resolves probable cause |
Tip: It is common to file simultaneously with NBI (criminal) and DTI (administrative) while requesting a bank-card chargeback—each track doesn’t bar the other.
4. Step-by-Step Workflow
- Demand Letter (Optional but Powerful) Give the scammer or the publisher 5–10 days to cure. Send via e-mail + registered mail; attach proof of receipt.
- Prepare Sworn Statement & Annexes • Use DOJ Cybercrime Office template (downloadable) or see Annex “D” of ACG primer.
- Filing & Docketing • Pay ₱75–₱2,000 filing fee depending on agency; get NBI reference number or IACAT case no.
- Forensic Preservation • Surrender devices only if subpoenaed; ask for chain-of-custody receipt.
- Monitoring • Agencies must give updates every 30 days under RA 9485 (Anti-Red Tape Act). Use FOI portal if silent.
- Resolution & Next Steps • Criminal: Prosecutor issues Information → file in RTC/MeTC of victim’s residence (RA 10175 sec. 21). • Civil: File damages suit or small-claims (≤₱400k) within one year from discovery for quasi-delict. • Restitution: Ask court to include restitution order or negotiate refund before arraignment.
5. Practical Tips to Improve Your Odds
| ✓ Do | ✗ Don’t |
|---|---|
| Capture live pop-ups with date/time overlay | Edit screenshots—defense will allege fabrication |
| Preserve original device in airplane mode | “Factory-reset” phone; digital footprint vanishes |
| File asap; cybercrimes have 12- to 15-year prescriptive period but data disappears fast | Wait months hoping publisher will “look into it” without pressure |
| Coordinate with other victims for a joint affidavit (helps prove pattern) | Post the suspect’s personal data online—may expose YOU to privacy or libel suits |
| Use the publisher’s official ticket portal first; logs show good faith | Rant only on social media; complaints there are rarely traceable |
| Ask for Assistance to Private Complainants desk at DOJ for free lawyers | Assume police will draft your affidavit; they won’t do it for you |
6. Special Situations
Minors Parents/guardians must represent children in filings (Art. 218, Family Code). For losses under ₱50k, seek mediation before formal charges to avoid retraumatizing the child.
Cross-Border Publishers (e.g., Garena SEA, miHoYo) Use the Mutual Legal Assistance Treaty (MLAT) route; NBI will transmit letters rogatory via the DOJ-OAC. Meanwhile, freeze local payment channels (Philippine-registered payment gateways) under AMLA rules.
Crypto-Token Rug Pulls File also with the Anti-Money-Laundering Council requesting a freeze order on identified wallets; AMLC may issue an ex-parte 20-day freeze if probable cause exists that assets are proceeds of unlawful activity (RA 9160, as amended).
Esports Betting Fraud Pagcor has jurisdiction if the platform advertises to Filipinos. Pagcor Regulation 13-01 lets you request administrative penalties and player reimbursement out of operators’ performance bonds.
7. Remedies Outside Government
- Card Chargebacks & E-wallet Disputes – Visa/Mastercard rules give 90–120 days from posting date. Provide police blotter or NBI Acknowledgment Receipt.
- Alternative Dispute Resolution (ADR) – For foreign publishers bound by Terms of Service with ICC/AAA arbitration clause; costs may be share-split.
- Class or Representative Suit under Rule 3, Sec. 12 of the Rules of Court (class must be so numerous that joinder is impracticable).
- Online Platforms’ “Player Support” Escalations – Steam, Google Play, Apple App Store refund channels have built-in scam categories; successful refunds often serve as evidence of wrongdoing in subsequent formal complaints.
8. Timelines & Prescription
| Offense | Prescriptive Period | When Clock Starts |
|---|---|---|
| Estafa (cyber-qualified) | 15 yrs | Date of discovery by offended party |
| Violation of RA 8484 | 10 yrs | Last unauthorized transaction |
| Consumer Act violations | 2 yrs (action) | Time defect/fraud discovered |
| Securities Code offenses | 5 yrs | Date of sale or offer |
9. Estimated Costs
| Item | Typical Range (₱) |
|---|---|
| Notarization of Affidavit | 200 – 500 |
| Police Certification / Blotter | 50 – 200 |
| NBI Filing Fees | 200 – 500 |
| Certified Bank Statements | 150 per page |
| Lawyer’s Acceptance Fee (private) | 20k – 150k (optional) |
| Barangay Mediation Fee | 0 – 500 |
Public prosecutors and DOJ legal assistance desks are free.
10. Frequently Asked Questions
“The scammer used a dummy Facebook account; can I still file?” Yes. Under RA 10175, venue may be where your device was used. Subpoena Facebook via the DOJ Mutual Legal Assistance Unit; they will release IP, log-ins, SIM number once protocol is followed.
“Is a screenshot admissible?” If properly authenticated. Rule 11 of the Rules on Electronic Evidence lets you testify that you personally captured it and describe the process (‘lay witness’ foundation). Having it hashed by an NBI digital forensic lab strengthens authenticity.
“Can I be liable too for gambling?” If you knowingly bet on an unlicensed game, you face penalties. However, reporting early and cooperating may qualify you for immunity as a state witness or for mitigated penalty.
“What if the publisher refuses to identify the cheater because of privacy?” Under Sec. 14(c)(1) Data Privacy Act, personal data may be disclosed for compliance with a legal obligation; subpoenas override their privacy policy.
11. Checklist Before You Hit “Submit”
- All screenshots include URL/time bar
- Affidavit notarized correctly (jurat, competent evidence of identity)
- Three USB copies or cloud links of evidence, sha-256 hashed
- Copy of demand letter & LBC tracking
- Proof of payments lost (receipts/e-statements)
- Contact person & phone for agency updates
12. Final Word
Online-game scams merge two worlds Filipinos love: gaming and digital finance. The laws might seem arcane, but the procedure is surprisingly straightforward once evidence is preserved. Act quickly, file with the correct agency (or two), and leverage both criminal and consumer-protection routes for the best shot at restitution and to stop scammers from preying on other players.
Stay safe, keep receipts, and may your loot always be legendary.