The rise of Financial Technology (FinTech) in the Philippines has democratized access to credit. However, it has also birthed a predatory ecosystem of unlicensed or non-compliant Online Lending Apps (OLAs). These entities often employ "shaming" tactics, debt-collection harassment, and life threats—actions that are not only unethical but strictly illegal under Philippine law.

If you are a victim of these practices, the legal framework provides several avenues for protection and prosecution.

1. Violations of the Data Privacy Act of 2012 (RA 10173)

Most OLA harassment begins with "contact list grabbing." Upon installation, many apps require access to your contacts, photos, and location. Using this data to inform your family, friends, or colleagues about your debt is a criminal violation.

Unauthorized Processing: Accessing your contacts for purposes other than what was consented to is illegal.
Malicious Disclosure: Disclosing a debtor's personal information with the intent to cause harm or humiliation.
Remedy: File a formal complaint with the National Privacy Commission (NPC). The NPC has the power to issue "Cease and Desist" orders and recommend the prosecution of the app's executives.

2. SEC Memorandum Circular No. 18 (Series of 2019)

The Securities and Exchange Commission (SEC) has issued specific guidelines regarding unfair debt collection practices. Prohibited acts include:

Threats of Violence: Any threat to the physical integrity of the person or their reputation.
Profane Language: Using insults or obscene language to shame the borrower.
False Representation: Claiming to be lawyers, court officials, or police officers to intimidate the debtor.
Contacting Others: Contacting people in the borrower's contact list (who are not co-makers or guarantors).
Remedy: Submit a complaint to the SEC Corporate Governance and Finance Department. The SEC can revoke the OLA’s Certificate of Authority to operate.

3. Cybercrime Prevention Act of 2012 (RA 10175)

Since the harassment occurs via digital platforms (SMS, Facebook, Email), it often falls under the jurisdiction of cybercrime laws.

Cyber Libel: Publicly posting about a person's debt with the intent to dishonor them.
Computer-Related Identity Theft: Using your profile picture or name to create fake accounts to harass others.
Remedy: Report the incidents to the PNP Anti-Cybercrime Group (PNP-ACG) or the NBI Cybercrime Division. They can assist in tracking the digital footprint of the harassers.

4. Revised Penal Code (RPC) Provisions

Serious threats and coercion are criminal offenses regardless of whether they happen online or offline.

Grave Threats (Art. 282): Threatening to inflict a wrong amounting to a crime (e.g., "I will kill you if you don't pay").
Light Threats (Art. 283): Threats not amounting to a crime but intended to intimidate.
Grave Coercion (Art. 286): Using violence or intimidation to compel someone to do something against their will (like paying an usurious interest rate).
Remedy: File a criminal complaint for Grave Threats or Coercion at the Office of the Prosecutor in your city or municipality.

Steps to Take for Victims

Action	Details
Document Everything	Take screenshots of all threatening texts, emails, and social media posts. Do not delete them.
Secure Your Data	Change your social media privacy settings and alert your contact list that your phone may have been compromised by a predatory app.
Verify the OLA	Check the SEC website to see if the OLA is a registered Lending Company or Financing Company. Many are "fly-by-night" operations.
Cease Communication	Once you have documented the threats, stop engaging with the harassers. They thrive on the psychological pressure they exert through interaction.

Important Jurisprudence Note

The Supreme Court and regulatory bodies have consistently held that debt is a civil matter, not a criminal one. Under the Philippine Constitution, no person shall be imprisoned for non-payment of a debt. While the OLA can sue you civilly for the money owed, they have no legal right to threaten your life or ruin your reputation. The moment they cross into harassment, the burden of criminal liability shifts to them.