How to Report and Dispute Unlawful Charges by Online Lending Apps in the Philippines

Prepared in a Philippine legal context. This is general information, not a substitute for tailored legal advice.

I. Overview

Online lending apps (OLAs) in the Philippines are primarily regulated by the Securities and Exchange Commission (SEC) (for lending/financing companies and their online platforms) and the National Privacy Commission (NPC) (for data privacy and harassment arising from misuse of personal data). If an OLA processes payments through banks, e-money issuers, or card networks, the Bangko Sentral ng Pilipinas (BSP) framework for consumer protection and chargebacks may also apply. Criminal conduct (extortion, threats, defamation at scale, doxxing) can involve the PNP Anti-Cybercrime Group (ACG) or NBI-CCD.

“Unlawful charges” typically means any amount the lender is not legally entitled to collect—e.g., fees not disclosed in the contract, usurious or unconscionable interest, duplicate fees, unauthorized debits, penalties assessed contrary to the agreement, or charges by unregistered or fake lenders.

II. Regulator Snapshot & What Each Covers

SEC (Lending & Financing): Registration of lending/financing companies and approval/notification of their online lending platforms; unfair debt collection prohibitions; deceptive or abusive practices; closure of unregistered OLAs; administrative fines/penalties; show-cause orders; revocation of registration.
NPC (Data Privacy): Unlawful access to contacts, “contact-list shaming,” harassment via mass messages, over-collection of data, consent defects, data breaches, failure to honor data subject rights.
BSP (Payments/EMIs/Banks): Dispute resolution for unauthorized debits, e-wallet or bank transfer issues, card chargebacks, and consumer assistance requirements for BSP-supervised institutions (BSFIs).
PNP-ACG / NBI-CCD: Cyber extortion, threats, grave coercion, libel/defamation online, identity theft, and related offenses.
Courts (Civil/Criminal): Small claims for refunds; damages for abusive collection (Civil Code arts. 19/20/21); criminal cases under the Cybercrime Prevention Act and the Revised Penal Code (as applicable).

III. Common Grounds to Dispute Charges

Undisclosed or Hidden Fees Fees not clearly disclosed before acceptance or buried in fine print that contradicts front-page terms.
Unconscionable Interest or Penalties Although the Usury Law ceilings are suspended, Philippine courts routinely strike down excessive rates and reduce them to reasonable levels when they shock the conscience (doctrine of unconscionability; see long-standing jurisprudence).
Charges Contrary to the Contract Billing outside agreed schedule; charging for services never rendered; early-payment penalties not stipulated.
Unauthorized Debits Debiting from linked bank accounts/e-wallets without fresh consent, or after account revocation.
Collection After Full Payment / Double Charging Duplicate posting, failure to apply payments, or continuing to assess interest after settlement.
Unregistered / Illegal Lenders Any “lender” operating without SEC registration or using an unapproved platform; contracts may be voidable and subject to enforcement action.

IV. Your Immediate Playbook (Step-by-Step)

Step 1: Preserve Evidence (Day 0–1)

Screenshots of the app’s pricing screens, repayment schedule, and all receipts.
Copies of the loan agreement, disclosures, consent screens, and privacy notices.
Logs of SMS/Chat/Email (including threats/harassment).
Bank/e-wallet statements showing the disputed debits.
Record of dates/times of app updates or changes in terms.

Step 2: Demand for Correction (Day 1–3)

Send a written dispute to the OLA (use the in-app help + email posted on its store listing/website). Request:

Itemized ledger and legal basis for each charge.
Immediate reversal of unlawful fees and a corrected payoff figure.
Suspension of collection and negative reporting while the dispute is pending.
Deletion/cessation of unlawful data processing (if harassment occurred).

Tip: Give a firm deadline (e.g., 7 calendar days) and ask for a written reply. Keep proof of dispatch.

Step 3A: If Payment Rails Were Used — File a Parallel Dispute (Day 1–7)

Bank/E-Wallet/Card: File a dispute/chargeback or unauthorized debit claim through the bank/e-wallet/card issuer’s consumer assistance channel.
Ask that they block future debits linked to the OLA mandate/token.
Provide the same evidence packet; reference your merchant dispute number.

Step 3B: If There’s Harassment or Data Misuse (Day 1–7)

NPC Complaint: Assert violations of the Data Privacy Act (unlawful processing, over-collection, lack of consent, unauthorized disclosure to contacts, failure to honor data subject rights).
Request cease-and-desist, deletion of unlawfully processed data, and administrative penalties.
PNP-ACG/NBI if there are threats, extortion, doxxing, or defamation at scale.

Step 4: Escalate to SEC (Day 7–14)

If the lender fails to fix the issue:

File an SEC complaint against the lending/financing company and its online platform for unlawful charges and any unfair collection practices (e.g., threats, public shaming, profane language, contacting non-consenting third parties, misrepresentation).
Attach proof the entity is operating online (screenshots/links), your contract, and all correspondence.
Ask for administrative action and a directive to correct/reverse charges.

Step 5: Civil Remedies (Anytime after documentation is complete)

Small Claims (no lawyer required up to the current monetary cap): Sue for refund of unlawful charges and damages (if quantifiable) in the appropriate first-level court where you reside or where the defendant may be sued.
Injunction/Cease-and-Desist: If ongoing harm exists (e.g., continuing harassment), consult counsel on an injunction and damages based on abuse of rights (Civil Code arts. 19/20/21) and unconscionable stipulations.

V. Special Issues & How to Handle Them

A. “Contact-List Shaming” & Privacy

OLAs cannot harvest and weaponize your contacts to coerce payment. That practice typically violates data minimization and proportionality principles, and may constitute unfair collection and privacy breaches.
In your NPC filing, enumerate: (1) nature of data collected, (2) what you consented to, (3) messages sent to contacts, (4) harm (reputational, emotional, employment). Request erasure, restriction, and administrative fines.

B. Interest, Penalties, and the Unconscionability Safety Valve

Even without statutory caps, courts reduce exorbitant rates and penalty structures. Keep a simple table showing principal vs. total charges vs. effective APR to demonstrate shockingly high burdens.

C. Unregistered or “Clone” Apps

If the app has no clear corporate identity or differs from the registered company name, include a “possible unregistered/clone” allegation in your SEC complaint and ask the SEC to verify registration and platform approval.

D. Negative Credit Reporting

If an OLA reported you negatively based on unlawful charges, include a deletion/correction request in your dispute and in regulator filings. Keep screenshots of the derogatory entry and your proof of payment/dispute.

E. Repayment While Disputing

If you can, tender the undisputed principal and lawful interest, stating clearly that payment is without prejudice to disputes on unlawful fees. This reduces exposure to additional penalties while preserving your claim.

VI. Templates You Can Use (Fill-in-the-Blanks)

1) Initial Dispute to OLA (Email)

Subject: Dispute of Unlawful Charges – [Your Name], Loan No. [XXXX]

Dear [Lender Name/Support Team]:

I dispute the following charges on my loan account [Loan No. ___]:

[List charge, amount, date, why unlawful]

These charges were not disclosed/are contrary to the agreement/are excessive/are unauthorized. I demand: (1) a detailed ledger and legal basis for each charge; (2) reversal of unlawful amounts and issuance of a corrected payoff figure; (3) suspension of collection and negative reporting while this dispute is pending; and (4) cessation of any harassment or processing of my contacts/data beyond lawful purposes.

Please respond in writing within 7 calendar days of receipt.

Attached: contract/screenshots/receipts/statements/ID.

Sincerely, [Full Name] [Mobile/Email] [Address]

2) Bank/E-Wallet/Card Dispute (If Unauthorized Debit)

Subject: Unauthorized Debit/Chargeback Request – Merchant: [OLA], Amount: [₱_], Date: [___]

I am disputing an unauthorized debit by [Merchant/OLA] on [date]. I did not authorize this transaction and/or the amount includes unlawful fees now under dispute with the merchant.

Please block future debits to this merchant and process reversal/chargeback as applicable. Supporting documents attached.

[Name, account no., contact details]

3) SEC Complaint Narrative (Attachment)

Parties: Your full details; lender’s corporate name (if known) and app/platform.
Facts: Timeline of borrowing, disclosures, what was charged, how discovered, escalation attempts.
Violations Alleged: Unlawful charges; unfair/abusive collection; possible unregistered operation.
Relief Sought: Order to reverse unlawful charges, administrative penalties, directive to cease unfair practices, confirmation of registration status.
Annexes: A–Z (screenshots, contracts, ledgers, statements, correspondence, IDs).

4) NPC Complaint Narrative (Attachment)

Data Involved: Contacts, photos, IDs, device info, messages.
Acts: Collection beyond necessity, use of contacts for shaming, messages to third parties, lack of consent, failure to honor data rights.
Harm: Emotional distress, reputational damage, workplace issues.
Relief: Cease-and-desist, erasure/restriction, sanctions, compensation (where available).
Annexes: Evidence of messages sent to contacts, call logs, screenshots.

VII. Evidence Checklist (Attach Where Relevant)

Government ID (for regulator verification)
Loan agreement + disclosure statements
In-app screenshots (pricing, ledger, payoff)
Email/SMS/chat threads and call recordings/transcripts
Bank/e-wallet/card statements
Proof of payments and reference numbers
List of contacts harassed (names/numbers/screenshots)
Any promotional materials (ads suggesting different rates)
Timeline document (one page, dated)

VIII. Practical Tips That Help Cases Succeed

Be specific and numeric. Quote exact amounts, dates, and clauses.
Use a single PDF packet with a table of contents and labeled annexes.
Keep everything in writing. If you must call, follow up by email summarizing what was said.
Secure your devices. Revoke app permissions to contacts, SMS, storage, and overlay; change e-wallet/bank passwords; enable transaction alerts.
Don’t be baited. If collectors threaten or insult, do not engage beyond “Please put it in writing.” Save the proof for regulators.
Mind limitation periods. File promptly; delays weaken equitable remedies.

IX. Frequently Asked Questions

1) The app says I consented to all fees. Am I stuck? No. Consent is not a blanket waiver of consumer protection. Hidden, misleading, or unconscionable fees can be voided or reduced.

2) Can they message my employer or relatives? Generally no. Contacting third parties to coerce payment is typically an unfair collection practice and a privacy violation, unless the third party is a co-borrower/guarantor or you gave clear, specific consent for that purpose.

3) Do I need a lawyer? Not for small claims within the monetary cap. For complex cases (injunctions, high damages, or criminal complaints), consult counsel.

4) Should I stop paying entirely while I dispute? If feasible, pay the undisputed principal/lawful interest and clearly reserve your rights. This reduces compounding penalties while you challenge the unlawful portion.

X. One-Page Action Plan (Copy/Paste)

Collect: Contract, ledger, receipts, screenshots, bank/e-wallet statements.
Dispute to OLA (7-day deadline).
Parallel dispute to bank/e-wallet/card (block debits/chargeback).
Privacy/Harassment: File with NPC; preserve all messages.
SEC Complaint: Unlawful charges/unfair collection; verify registration.
Escalate: PNP-ACG/NBI for threats/extortion/doxxing.
Court (Small Claims/Civil) for refund/damages if not resolved.
Secure accounts & permissions; document everything.

Final Note

Keep communications calm, chronological, and documented. Philippine regulators have repeatedly acted against abusive OLAs; well-organized complaints with clear math and screenshots are the fastest path to reversals and sanctions.