Online Game Scam Legal Complaints in the Philippines: A Complete Guide

General information only, not legal advice. For an actual case, consult counsel or the DOJ/City or Provincial Prosecutor. No web sources were used per your instruction.

1) What counts as an “online game scam”?

Any deceitful scheme in or around a game—PC/console/mobile/browser—designed to obtain money, in-game assets, or account access. Common patterns:

Fake sellers/buyers of items/currency/accounts (no delivery after payment; chargeback abuse).
Account takeovers (phishing/OTP interception/password resets).
In-game trading fraud (bait-and-switch, duplicate-item hoaxes).
Impersonation of GMs/admins/support to extract credentials or “verification fees.”
Malware/cheat loaders that install stealers or keyloggers.
Gift code / top-up scams using stolen cards/mules.

If money, property, data, or access is obtained by deceit or unauthorized computer acts, you likely have criminal and civil claims.

2) Legal foundations (Philippine context)

A. Estafa / Swindling (Revised Penal Code, Art. 315, as amended by RA 10951)

Core idea: Deceit or fraudulent acts causing damage; amount-dependent penalties.
Typical fits: Fake seller/buyer; “investment” or “VIP loot box” schemes; misrepresentation to induce payment.
Online effect: If done “by, through, or with the use of ICT,” penalty is one degree higher (Cybercrime Act §6).

B. Cybercrime Prevention Act of 2012 (RA 10175)

Illegal access (§4(a)(1)); data/system interference (§4(a)(2)–(3)) → account takeovers, disabling 2FA, deleting inventories.
Computer-related fraud (§4(b)(2)) → manipulation of data/transactions to obtain economic benefit (e.g., altering logs, duped trades).
Computer-related identity theft (§4(b)(3)) → impersonating you/admin to solicit assets/money.
Penalty lift: Crimes under the RPC done via ICT → one degree higher (§6).
Jurisdiction/venue: Designated Cybercrime Courts; venue where any element occurred or where any part of a computer system is located; limited extraterritorial reach when effects or acts hit the Philippines.

C. Access Devices Regulation Act (RA 8484)

Covers credit/debit/e-wallet fraud, use of stolen cards/access devices for top-ups or in-game purchases.

D. E-Commerce Act (RA 8792) & Rules on Electronic Evidence

Electronic documents (screenshots, chat logs, emails, server logs) and electronic signatures can prove transactions; authenticity → hashes/metadata, custodian testimony.

E. Data Privacy Act (RA 10173)

If a platform mishandled your personal data enabling the scam (e.g., breach), you may have a separate complaint with the NPC and potential civil liability for damages.

F. Anti-Money Laundering (RA 9160, as amended)

Scammers and money mules risk AML exposure. You can request coordination for freezing/forfeiture of proceeds once identified.

3) Civil vs. criminal routes (you can do both)

Criminal: Estafa and/or cybercrime offenses via the Office of the Prosecutor; police investigation by PNP-ACG or NBI-CCD.
Civil:
- Quasi-delict (Art. 2176 Civil Code) or breach of contract to recover money, property, and damages.
- Small Claims (no lawyers required) for money claims up to the current threshold (recent rules peg this at ₱1,000,000; check the latest circular in your court).
Insurance/Chargebacks: Limited role, but e-wallets/issuers have dispute windows; timely notices matter.

4) Elements you’ll need to prove (typical patterns)

A. Fake seller / non-delivery

You paid (receipt/transfer ref/txn ID).
Misrepresentation or deceit before or at the time of payment (ads, promises, screenshots, identity).
No delivery or delivery of something substantially different.
Damage: loss of money/asset.

B. Account takeover / item theft

Unauthorized access or credential capture (phishing link, OTP request, IP logs).
Data/system interference or fraudulent transactions (trades, gifting, liquidations).
Damage: lost items/currency/time/money.
Attribution: link the actor to devices/accounts (IP/device IDs, login timestamps, KYC of receiving wallets, exchange records).

C. Impersonation of admins/mods

Deceit by posing as authority;
Reliance (you followed instructions/paid/handed credentials);
Damage;
ICT use → penalty uplift.

5) Evidence master plan

Preserve fast

Screenshots/recordings of chats (full threads, timestamps, handles), trade screens, profile pages, listings, payment receipts, transaction hashes/IDs.
Email/SMS/OTP logs; device notifications.
Server/dash logs (request from platform via preservation letter).
E-wallet/bank statements; payment processor dispute refs.
IP/device evidence: ask platforms for access logs; note IPs, device fingerprints.

Authenticate properly

Compute SHA-256 hashes for exported files; keep originals read-only.
Maintain an Evidence Index with file names, hashes, sources, date/time captured.
Get a custodian affidavit (you or IT person) to explain how the copies were created and preserved.

Chain of custody

If you surrender devices or USBs, seal and log transfers (who/when/why/seal numbers).

6) Where to file & who investigates

Police/Investigators:
- PNP-Anti-Cybercrime Group (ACG) – intake/blotter, digital forensics, coordination with platforms/e-wallets.
- NBI-Cybercrime Division (CCD) – parallel venue for high-tech cases.
Prosecutor: File a Complaint-Affidavit with exhibits (screenshots, receipts, logs, preservation response).
Cybercrime Courts (RTC): Handle RA 10175 offenses and ICT-facilitated RPC crimes after the prosecutor files the Information.

For small-value restitution or when identity is clear, Small Claims can be faster for civil recovery (money only).

7) Damages you can claim (civil)

Actual/Compensatory: stolen balances, cost of items/currency/accounts, chargeback fees, lost subscription time, device repair, travel/time costs (receipted).
Moral damages: anxiety, humiliation (particularly for identity theft or doxxing).
Exemplary damages: to deter grossly fraudulent conduct.
Temperate damages: when loss is certain but not fully receipted.
Attorney’s fees (in proper cases) and 6% p.a. legal interest from the proper reckoning date.

8) Platform remedies (do these in parallel)

Immediate in-app report (get ticket numbers).
Account freeze request on the recipient (trade partner) and mule accounts; provide txn IDs/screenshots.
Preservation request: ask for 90–120 days hold on logs, chat history, device fingerprints, payment references, and KYC of counterparties.
Chargeback/dispute with issuer/e-wallet within their time limits (often short: 7–30–60 days tiers).
Two-way KYC: some platforms will disclose basics to law enforcement upon subpoena; hand investigators your ticket numbers.

9) Step-by-step: Criminal complaint pack

Narrative: who, what, when, where, how (chronology with timestamps).
Charges to allege (pick what fits):
- Estafa (Art. 315);
- RA 10175: illegal access, computer-related fraud, identity theft;
- RA 8484 if access devices were used;
- (Optional) Data Privacy violations if a breach in the platform caused the loss.
Annexes:
- A: Payment proofs/txn IDs;
- B: Chats/emails (full threads);
- C: Screens/recordings of trade;
- D: Platform tickets & preservation reply;
- E: IP/login logs (if available);
- F: E-wallet/bank statements;
- G: Evidence Index + hash values;
- H: Affidavit of custody/authentication.
Relief: prosecution + restitution and forfeiture of proceeds/instruments.
Venue: where any element occurred (your payment, their solicitation, your device location) or where any part of the system sits; file at your City/Provincial Prosecutor and coordinate with PNP-ACG/NBI-CCD.

10) Civil route options & timelines

Demand letter (attach evidence; give a payment deadline; warn of cybercrime/estafa filing).
Small Claims: money claims (no damages for pain/suffering here—money only), up to the current cap; direct to MTC/MeTC with verified Statement of Claim and attachments.
Ordinary civil action (RTC/MTC depending on amount) for restitution + damages.
Prescription:
- Estafa: time limits depend on penalty band (amount-based under RA 10951).
- Cybercrime offenses: generally follow their parent crimes; act promptly.
- Civil quasi-delict/contract: usually 4 years (quasi-delict) / 10 years (written contract), but don’t cut it close—evidence goes stale quickly.

11) Defenses to anticipate (and counters)

“It’s just a TOS issue.” → Criminal deceit/illegal access is beyond mere TOS violation.
“Victim was careless with 2FA.” → Negligence doesn’t excuse illegal access or fraud; at most it may affect mitigation, not criminal liability.
“No loss.” → Show valuation (market price/official shop price/exchange rate) and opportunity loss (subscription days, tournament entries).
“Impostor used my name.” → Tie the actor via receiving accounts, IP/device IDs, KYC, or cash-out trail (mules).

12) Valuation of in-game assets

Courts prefer objective, contemporaneous references:

Official shop prices (top-ups, skins, passes).
Publisher exchange rates (gems→PHP; coins→USD→PHP).
Secondary market (if recognized by publisher) with screenshots and dates.
Your acquisition cost (receipts), time-investment evidence may support temperate damages when resale is restricted.

13) Practical checklists

A. Evidence & process

Police/NBI blotter & ticket numbers
Full chat/email threads (export + hash)
Payment proofs (txn IDs, wallet tags)
Platform preservation & freeze requests
Device scan results (malware/stealer check)
Statement of losses (table with dates/amounts)
Draft Complaint-Affidavit + Custodian Affidavit

B. Security hardening (so it doesn’t happen again)

Reset passwords; enable app-based 2FA; revoke sessions
New email alias just for game account recovery
Secure devices (OS updates, antivirus, authenticator backups)
Lock SIM; disable call/SMS forwarding; set bank/app alerts
Educate co-players: no OTP sharing, verify handles via in-app methods

14) Templates (ready to adapt)

A. Complaint-Affidavit (criminal)

Complaint-Affidavit I, [Name], Filipino, of legal age, residing at [Address], depose:

On [date/time], via [game/platform/app], respondent [username/real name if known] [sold/solicited/accessed] [item/currency/account] under the false representation that [state deceit].

Relying on said representations, I [paid/transferred/provided credentials] amounting to ₱[amount] / [asset], transaction ID: [ref].

Respondent [failed to deliver/withdrew items/accessed my account/transferred items], causing me damage of ₱[amount] (Annex A valuations).

Acts were committed by/through the use of ICT via [app/site/device].

I charge respondent with Estafa (Art. 315, RPC as amended) and violations of RA 10175 ([illegal access / computer-related fraud / identity theft]) and other related laws ([RA 8484], if applicable).

Annexes: A (payments), B (chat/email threads), C (trade logs/screens), D (platform tickets), E (login/IP logs), F (bank/e-wallet statements), G (Evidence Index & hashes), H (Custodian Affidavit). [Signature] • Affiant Jurat/Verification before the prosecutor/notary.

B. Preservation / Freeze Request to Platform

Subject: Urgent Preservation & Freeze – Fraudulent Activity (Case Ref: [ticket/blotter no.]) Please preserve for 120 days and, where your policy allows, freeze assets in accounts [usernames/IDs] tied to [txn IDs, dates]. Kindly preserve: (i) login/IP/device fingerprints; (ii) chat logs; (iii) trade/transfer logs; (iv) payment references; (v) KYC/identity of counterparties. Law enforcement will serve formal process. Attached: ID, screenshots, police/NBI reference.

C. Civil Demand Letter

Dear [Name/Handle], You obtained ₱[amount]/[assets] from me on [date] through [misrepresentation/unauthorized access]. Demand is made for [refund/return] within 5 days of receipt, failing which I will file criminal charges for Estafa and Cybercrime offenses and a civil action for restitution, damages, interest, and fees. [Signature/Contact]

D. Evidence Index (sample header)

Annex	File	SHA-256	Description	Source	Date/Time
A-1	txn_2025-08-21.pdf	…	GCash payment ₱5,000	GCash export	2025-08-21 19:05
B-3	chat_full_export.html	…	In-app DM thread	Game client	2025-08-22 13:40

15) Red flags & pro tips

Too-good prices / rush pressure / off-platform payments → classic scam setup.
Mod/GM impersonation → verify via official in-app badges/workflows.
“Verification fee” or “collateral” asks → assume fraud.
Always trade within the game’s secure trade flow; off-platform = little platform help.
Keep running screenshots during trades; record your screen when possible.
Move early: CCTV/servers/e-wallet logs rotate quickly.

16) Quick action plan (one page)

Capture & preserve: screenshots, receipts, chat threads (export + hash).
Report in-app; request preservation & freeze; open a police/NBI case.
Lock down your accounts/devices; reset passwords; enable app-based 2FA.
Send demand and file complaint-affidavit (estafa + RA 10175 + RA 8484 if applicable).
Pursue civil recovery (Small Claims/ordinary civil); track 6% p.a. interest.
Coordinate with investigators for KYC/IP/device data via subpoena/warrant.
Consider AML angle to freeze proceeds if flows are identified.

Final cautions

Penalties for estafa scale with the amount defrauded; RA 10951 governs thresholds.
Crimes done via ICT get a penalty upgrade.
Venue and jurisdiction rules for cybercrime are specialized—file where you can show a clear element occurred.
If a platform’s data mishandling enabled the scam, a separate privacy complaint may be viable.

If you want, I can turn this into a printable Complaint Kit (Word/PDF) with fillable fields, plus a spreadsheet that auto-totals your losses and adds interest.