How to Stop Harassment by Online Lending Apps in the Philippines: A Step-by-Step Legal Guide

Philippine context. This article explains your rights and concrete actions to stop abusive collection tactics by online lending apps (OLAs). It’s organized so you can act immediately, then escalate to regulators and law enforcement if needed.

1) Know Your Rights (and the Laws That Protect You)

Debt collection cannot be abusive. The Financial Consumer Protection Act of 2022 (RA 11765) prohibits unfair, deceptive, abusive, or unconscionable collection practices by supervised financial service providers. Regulators (SEC for lending/financing companies; BSP for banks and certain non-banks) can investigate and sanction violators.
Harassment and “contact shaming” are illegal. The SEC’s Prohibition on Unfair Debt Collection Practices (SEC Memorandum Circular No. 18, s. 2019) bars threats, use of profane/obscene language, public humiliation, false representations (e.g., pretending to be a lawyer/police), and contacting your family, employer, or friends to expose your debt.
Your personal data is protected. The Data Privacy Act of 2012 (RA 10173) requires lawful, transparent, and proportional processing of personal data. Scraping your contact list or blasting third parties is generally not proportional to loan collection and may violate your and your contacts’ rights. You can withdraw consent and demand erasure or restriction of processing.
Criminal laws may apply. The Revised Penal Code penalizes grave threats (Art. 282), grave coercion (Art. 286), and unjust vexation/other similar coercions (Art. 287). Cybercrime Prevention Act (RA 10175) can apply to online libel/defamation, computer-related threats, and harassment done via electronic means.
No prison for debt. The Constitution (Art. III, Sec. 20) forbids imprisonment for nonpayment of debt. Criminal liability may arise only for separate crimes (e.g., estafa), not mere inability to pay.

2) Immediate Steps (Today)

Preserve evidence (don’t delete).
- Take screenshots (include timestamps, sender number/account, message headers).
- Export call logs/voicemails.
- Save the app’s name, developer, and version; keep loan documents, receipts, and chat transcripts.
Lock down the app’s permissions.
- On your phone: Settings → Apps → [App] → Permissions → deny Contacts, Storage, SMS, Call logs, Camera, Microphone, and Location.
- If you must uninstall, capture evidence first; then uninstall and clear cache/data.
- Enable call/SMS blocking and spam filters on your device and messaging apps.
Stop third-party harassment right away.
- Send a short message to any friends/family/co-workers who received shaming texts:
  
  “I’m resolving a personal loan matter. Any messages/calls about me are unauthorized and may violate Philippine privacy and consumer laws. Please block/report the sender and do not engage.”
Demand they cease unlawful collection (formal notice). Send a Cease-and-Desist + Withdrawal of Consent (see template below) through all available channels of the lender (in-app support, email, contact form). Ask for written confirmation.

3) Decide Who Regulates Your Lender

If it’s a lending or financing company (most OLAs): Securities and Exchange Commission (SEC) has jurisdiction (licensing, unfair collection, OLP compliance).
If it’s a bank, e-money issuer, or BSP-supervised non-bank (some BNPL, digital banks): Bangko Sentral ng Pilipinas (BSP) handles the case.
If you’re unsure, file with both SEC and the National Privacy Commission (NPC); they coordinate and can redirect.

Tip: Legit lenders must be SEC-registered and have a Certificate of Authority to operate as a lending/financing company. Their online lending platforms must also be properly disclosed to the SEC. If the “app” is not tied to a licensed entity, treat it as illegal and report it.

4) Escalation Path (Step-by-Step)

A) Formal Notice to the Lender (Day 1–2)

Send your Cease-and-Desist + Data Rights letter (template below). Ask for:

Immediate halt to all harassment and contact-shaming.
A direct, non-abusive channel for account resolution.
Their registered company name, SEC/BSP registration numbers, and complaints officer contact.
Data minimization: deletion of your contact list and any third-party data harvested from your device.
A copy of your data (data portability) and privacy policy relied upon.

Keep proof of dispatch (email sent receipts, ticket numbers, screenshots).

B) Regulator Complaints (Day 2–7)

SEC (if lending/financing company / OLA)
- Basis: SEC MC No. 18 (2019) and RA 11765.
- Ask for investigation and sanctions for unfair debt collection.
- Attach evidence: shaming messages, call logs, app details, your letter, and any responses.
BSP (if bank/EMI/BSFIs)
- Basis: RA 11765 and consumer protection/market conduct rules.
- Request supervisory action for abusive collection and misconduct.
National Privacy Commission (NPC)
- Basis: RA 10173 (Data Privacy Act).
- Complain about unlawful processing, contact harvesting, disclosure to third parties, failure to implement proportional safeguards, and refusal to honor data subject rights.
- Include: list of harassed contacts, samples of third-party messages, and your withdrawal-of-consent notice.

NPC can issue Compliance/Enforcement Orders; SEC/BSP can sanction, suspend, or revoke authorizations. Parallel filings are normal.

C) Law Enforcement (Anytime Harassment Crosses the Line)

PNP Anti-Cybercrime Group (ACG) / NBI Cybercrime Division File if there are threats, extortion, defamation, doxxing, or identity misuse. Bring a printed dossier (evidence checklist below) and execute a sworn statement.
Possible crimes: grave threats, grave coercion, unjust vexation, cyber-libel, computer-related offenses under RA 10175.

D) Telco/NTC Measures

Ask your telco to block specific numbers and report text spam/harassment.
You may also file with the National Telecommunications Commission (NTC) for persistent nuisance calls/texts. Provide the SIM numbers, dates, and message samples.

5) If Your Employer or Contacts Are Targeted

For employers/HR: Treat shaming blasts as unauthorized processing of personal data. Instruct staff to ignore, block, and escalate to HR/Legal. Keep copies as evidence only.
For your contacts: They each have rights under the Data Privacy Act and may file their own NPC complaint for misuse of their numbers and personal data.

6) Handling the Debt Itself (Safely)

You still owe legitimate amounts you borrowed, but only lawful interest/fees/charges. Request a Statement of Account itemizing principal, interest, penalties, and payments.
Negotiate in writing (email/chat exportable), avoid verbal-only deals, and keep receipts.
Pay only to official company accounts (not personal wallets).
If charges look abusive or the entity appears unlicensed, prioritize regulatory complaints first; do not be coerced into on-the-spot payments under threat.

7) Evidence Checklist (Bring to SEC/BSP/NPC/PNP/NBI)

Your ID and contact details.
Loan documents, screenshots of app profile, in-app loan page, and privacy policy.
Screenshots of messages/calls (showing numbers, handles, timestamps).
List of third parties who were contacted (names, numbers, relationship).
Phone settings screenshots showing permissions and app access.
Your Cease-and-Desist letter and proof of receipt by the lender.
Any payments made (receipts, bank slips).
Employment letter (if workplace was harassed), attesting to receipt of shaming messages.

8) Templates You Can Use

A) Cease-and-Desist + Withdrawal of Consent (send to the lender)

Subject: CEASE AND DESIST; WITHDRAWAL OF CONSENT; DATA RIGHTS INVOCATION

[Date]

[Company Legal Name]
[Address / Email / In-App Ticket ID]

I am [Full Name], borrower under account/reference no. [XXXX]. Your representatives and/or systems have engaged in abusive debt collection, including [harassment/public shaming/contacting my relatives/employer], which are prohibited by RA 11765 and SEC MC No. 18 (2019). These actions also violate my and my contacts’ rights under RA 10173.

Effective immediately, I:
1) DEMAND that you CEASE AND DESIST from any and all forms of harassment, public shaming, or third-party communications.
2) WITHDRAW any consent you rely on to access/process my device contacts, messages, photos, location, or other data not strictly necessary for account servicing.
3) DEMAND ERASURE of any third-party data obtained from my device and restriction of further processing that is not lawful, necessary, and proportional.
4) REQUEST your SEC/BSP registration details, the identity and contact of your complaints officer, and a direct non-abusive channel for account resolution.
5) REQUEST a complete Statement of Account and a copy of all personal data you hold about me.

Failure to comply will be reported to the SEC/BSP and National Privacy Commission, and any criminal acts will be referred to law enforcement under the Revised Penal Code and RA 10175.

Please confirm compliance within five (5) calendar days.

Sincerely,
[Name]
[Email / Mobile]

B) Statement to Contacts (if they were messaged)

Please disregard messages or calls about me from any loan app/collector. They are unauthorized and may violate Philippine privacy and consumer laws. Kindly block the sender and avoid responding. Thank you for letting me know when you receive such messages.

C) Complaint Outline (attach your evidence)

1) Parties and app details (app name, developer, company legal name if known).
2) Facts (timeline of loan and harassment).
3) Violations (SEC MC No. 18; RA 11765; RA 10173; applicable RPC/RA 10175 provisions).
4) Evidence list (screenshots, call logs, contact list blasts, permissions history).
5) Relief sought (investigation, sanctions, cease-and-desist, data erasure, compliance orders).

9) Practical Do’s and Don’ts

Keep everything in writing; save PDFs of chats and emails.
Use one calm message per day in negotiations; do not escalate tone.
Tell your contacts to block and not engage.
Check whether the lender is properly licensed before paying.

Don’t

Don’t surrender more personal data (IDs/selfies/contacts) than necessary.
Don’t pay to unknown personal accounts.
Don’t be pressured into same-day repayments under threat.
Don’t post your case publicly with sensitive info—preserve evidence privately first.

10) Special Situations

They used your selfie/ID to shame you: This implicates unlawful processing and possibly defamation. Include those images in your NPC and law-enforcement complaints.
They messaged your boss/HR: Provide HR with a short memo explaining their privacy obligations to safeguard your data and refrain from circulating shaming messages; route everything to Legal/HR.
They threaten “criminal cases” for non-payment: Remind them non-payment is civil, not criminal. Threats and coercion are themselves unlawful.
You already fully paid: Demand a closure letter/zero balance and removal of your data not needed for compliance/retention.

11) Decision Tree (Quick Reference)

Is the entity a bank/EMI/BSFI?
- Yes → File with BSP (+ NPC if data abuses).
- No / OLA → File with SEC + NPC.
Are there threats/defamation/extortion?
- Yes → PNP-ACG/NBI + regulators.
- No → Proceed with regulator complaints and civil/administrative remedies.
Were your contacts harassed?
- Yes → Include in NPC filing; ask contacts to file too.

12) Frequently Asked Questions

Will filing complaints stop the harassment? Often, yes—regulatory risk deters violators. Keep reporting repeat incidents.
Can they sue me for non-payment? They can pursue civil collection, but cannot legally threaten, shame, or harass you or your contacts to force payment.
Can I be jailed for debt? No—there is no imprisonment for non-payment of debt. Separate crimes are different and fact-specific.
Should I pay while complaints are pending? If the entity is licensed and the amount is legitimate, you may negotiate terms in writing. If it appears unlicensed/abusive, prioritize regulator/law-enforcement actions.

13) Final Reminders

Keep a daily log of incidents (date, time, number, summary).
Use a separate email for filings to keep your inbox organized.
Update your complaints when new harassment occurs.
Consider consulting a Philippine lawyer for tailored advice, especially if large sums or workplace issues are involved.

Disclaimer

This guide is for general information in the Philippine context and is not legal advice. Laws and enforcement practices can evolve; for specific situations, consult qualified counsel.