Illegal Practice of Dentistry Without a PRC License (Philippines): A Complete Legal & Practical Guide

For patients, LGUs, school administrators, employers, and licensed professionals who need to spot, stop, or prosecute unlicensed dental practice. This guide explains the law, red flags, penalties, remedies, and step-by-step complaint paths in the Philippine setting.

1) Core law & who regulates

Primary statute: Philippine Dental Act of 2007 (Republic Act 9484).
Regulators: Professional Regulation Commission (PRC) and the Professional Regulatory Board of Dentistry (Board).
What the law does: Defines the practice of dentistry, creates licensure and ethics rules for dentists, dental hygienists, and dental technologists, and sets criminal/administrative penalties for unlicensed practice, use of false titles, illegal clinics, and aiding/abetting.

Short rule: No PRC license → no dental practice. “Helping” an unlicensed operator can also make you liable.

2) What counts as “practice of dentistry”

RA 9484 treats as practice of dentistry activities such as:

Examining, diagnosing, prescribing, planning, or treating conditions of the teeth, gums, jaws, and oral cavity;
Surgical procedures (e.g., extractions, impactions), restorations, endodontics, periodontics, prosthodontics (dentures, crowns, bridges), orthodontics (braces/aligners), implant dentistry;
Taking impressions, fabricating or delivering prostheses to the public (delivery to patients is a dentist’s act; dental technologists work through a dentist);
Radiographic exams (dental X-rays) and prescribing dental drugs within scope;
Advertising or holding out to the public as a dentist or offering dental services for a fee.

Teledentistry/online counts too: diagnosing, treatment planning, or prescribing through apps or chat is still practice and requires a PRC-licensed dentist (with identity and PRC number shown).

3) Who may lawfully do what

Dentist (PRC-licensed): May diagnose, prescribe, and treat; perform all dental and oral surgical procedures within competence; order X-rays; prescribe medicines within dental scope.
Dental Hygienist (PRC-licensed): Preventive procedures (e.g., scaling, prophylaxis) under supervision of a dentist; no diagnosis/prescription; no independent practice beyond preventive scope defined by law.
Dental Technologist (PRC-licensed): Laboratory fabrication/repair of prostheses on dentist’s written prescription; no direct patient contact to diagnose, take impressions, fit or deliver appliances.
Students/Interns: May perform limited tasks only inside accredited schools/clinics and under direct supervision of a PRC-licensed dentist.
Foreign dentists: May practice only with a special temporary permit (e.g., for missions, lectures, or institutional employment) and subject to reciprocity/permit requirements.

4) What constitutes illegal practice

Any of the following without a valid PRC license/permit:

Performing clinical dental acts (exam, diagnosis, extraction, fillings, root canals, surgery, braces/aligners, implants, whitening with clinical techniques, periodontal treatment, denture fitting/delivery).
Dental lab techs or hygienists treating the public directly, taking impressions, fitting/delivering dentures or aligners, or advertising services to patients.
Beauty salons/spas/“dental studios” offering whitening, braces/aligners, dentures, or extractions.
Online sellers marketing DIY braces/aligners/dentures or “virtual consultations” without a PRC-licensed dentist who actually examines and prescribes.
Using fake/borrowed PRC IDs, expired licenses, or claiming the title “dentist” or similar in ads, signboards, or social media.
Operating clinics without PRC-licensed dentists (and required business/LGU permits), or using a “dummy” licensee who is absent.

Aiding/abetting is also unlawful: owners/managers who employ or rent space to unlicensed operators; licensed dentists who cover for illegal operations; landlords knowingly leasing to “back-alley” dental shops; schools or employers permitting unlicensed dental acts.

5) Penalties & exposure

Under RA 9484 (and related penal provisions), expect stackable consequences:

A) Criminal (unlicensed practice, false titles, aiding/abetting)

Imprisonment: typically 2 to 5 years; and/or
Fines: typically ₱200,000 to ₱500,000;
Corporate officers/owners who allowed the violations may be personally liable.
Counterfeit IDs/documents can add falsification/estafa charges under the Revised Penal Code.

B) Administrative / regulatory

Cease-and-desist, clinic closure, and confiscation of illegal equipment;
PRC sanctions against licensed professionals who aided violations (suspension/revocation, fines).

C) Civil liability

Patients can claim actual, moral, and exemplary damages for injury, botched work, infections, or misrepresentation; fees can be refunded; courts can order permanent injunctions.

Aggravators: Pediatric victims, serious bodily injury, use of sedatives/anesthetics, radiation (X-ray) exposure without licensing, and repeated offenses.

6) Red flags for patients & LGUs

No PRC ID on display; receipt or prescription without PRC number and full name; cash-only, no official receipt.
Prices far below market for braces/aligners/dentures; insistence on DIY impression kits; “just send photos.”
Clinic hours staffed by assistants only; the “dentist” is never present; you meet a “doctor” who won’t show ID.
Home service surgeries/extractions; procedures done in salons, stalls, or apartments with no infection control.
Social media pages titled “dental studio/clinic” with no dentist named.

7) Special scenarios

Direct-to-public denture making: Illegal. Dental technologists must work through a dentist; only dentists can take impressions, fit, and deliver prostheses.
DIY/online aligners: Diagnosis, orthodontic planning, and appliances require a dentist’s exam, records, and supervision; selling trays without such is illegal practice.
Teeth whitening by non-dentists: When it involves peroxides, gingival barriers, trays, or in-office systems, that’s a dental procedure.
Mission work: Foreign or local missions still require PRC authorization (special permits), local government coordination, and standard infection control.
Radiation use (X-rays): Requires qualified personnel and compliant equipment; unlicensed operators running X-ray units stack violations (radiation control + illegal practice).

8) How to file a complaint (step-by-step)

A) If you’re a patient or citizen

Preserve evidence: photos/videos of the person/clinic, screenshots of chats/ads, receipts, prescriptions, business cards, product packaging, copies of IDs used.
Medical documentation: post-treatment records, pictures of injuries, second-opinion reports, lab results.
File with PRC (Legal/Regulatory Division or any PRC Regional Office) a Verified Complaint (sworn affidavit) naming the respondent, clinic address, dates, acts, harm, and attaching evidence.
Parallel reports (as facts warrant):
- LGU (Business Permits/Mayor’s Office) for closure of illegal clinic;
- PNP/NBI for criminal investigation/arrest;
- DOH/health office for public health hazards (infection control, radiation);
- Consumer protection (DTI/LGU) for fraudulent advertising.
Seek civil remedies: Demand letter → civil suit for damages/refund/injunction if injured or defrauded.

B) If you’re LGU enforcement / landlord / mall admin

Require PRC license of on-site dentists and DTI/SEC + Mayor’s Permit; deny/void leases to non-compliant “dental” tenants.
Joint ops with PRC + PNP for raids/closure; document inventory and tag equipment.
Post public advisories against identified illegal operators.

9) Inside the PRC case (what to expect)

Docketing → Summons to respondent → Answer (10–15 days typical) → Conference/Hearing (evidence marking) → Position papers → Decision (penalties/fines) → MR/Appeal to PRC Commission → Rule 43 judicial review (CA), if any.
PRC may issue cease-and-desist during proceedings in clear cases; coordinate with LGU/PNP for enforcement.

10) Defenses you’ll hear (and why they fail)

“I’m only a technician/hygienist” → You still can’t diagnose, take impressions, fit/deliver appliances, or treat the public directly.
“A dentist supervises online” → Remote “covering” without actual examination/records is non-compliant.
“We’re cheaper for the poor” → Charity isn’t a defense to criminal practice. There are lawful missions/government clinics.
“The patient consented” → Consent does not legalize unlicensed practice (nor waive public policy).

11) Liability of enablers

Clinic owners/managers, landlords, ad agencies, and platform sellers who knowingly facilitate unlicensed services risk criminal aiding/abetting and civil liability.
Licensed dentists who lend their name/PRC to cover illegal operations face PRC discipline (suspension/revocation) plus criminal exposure.

12) Patient remedies & damages

Refund of fees;
Medical costs (corrective treatment, hospitalization), lost income, moral/exemplary damages for pain, disfigurement, or humiliation;
Injunction to stop continued illegal practice;
Criminal complaints for illegal practice, estafa (if deceived), falsification (fake IDs/receipts).

Evidence wins cases: keep before/after photos, timelines of pain/complications, and receipts for corrective care.

13) Compliance checklist (for legitimate operators)

PRC license (dentist) current; displayed in clinic; PRC number on receipts/prescriptions.
Hygienists/technologists: PRC licenses current; written protocols for dentist supervision/prescriptions; no direct public offerings.
Business permits complete (DTI/SEC, BIR, Mayor’s Permit); infection-control SOPs; sharps/biowaste handling.
Radiographic units compliant; qualified operator; radiation safety documents.
Advertising accurate: no “specialist” titles unless justified; no misleading cure claims; identity of responsible dentist shown.
Records: patient charts, prescriptions, lab work authorizations retained per standards.

14) One-page complaint template (patient → PRC)

Affidavit-Complaint I, [Name], of legal age, [address], state:

Respondent [Full Name/Alias] operates at [address/page] and offers [dental services] without a PRC license.

On [dates], respondent performed [acts] on me/others, causing [injury/loss].

I attach Annexes A-__: screenshots/receipts/photos/medical reports/ID checks. Prayer: Issue cease-and-desist, impose penalties under RA 9484, and coordinate with PNP/LGU for closure and prosecution. [Signature] (Sworn before a notary)

15) Bottom line

Dentistry is a licensed profession. Exams, diagnosis, impressions, braces/aligners, dentures, extractions, whitening with clinical materials—all require a PRC-licensed dentist (with hygienists/technologists only within their defined roles).
Unlicensed practice triggers criminal, administrative, and civil liability—including for those who enable it.
Patients & LGUs should act fast: preserve evidence, file with PRC, and coordinate with enforcement for closure and prosecution.
Legitimate providers must keep licenses, permits, supervision, records, and advertising clean—and refuse any arrangement that smells like “covering.”

This guide is general information and not legal advice. For high-risk events (serious injury, pediatric cases, radiation exposure, cross-border operators), consult counsel immediately and coordinate PRC/LGU/PNP action in parallel.