Unlicensed dental practice is both a public safety risk and a criminal offense in the Philippines. This article explains (1) what conduct is considered “practice of dentistry,” (2) who may be liable, (3) practical ways to document and report, and (4) what to expect after filing a report—within the Philippine legal and enforcement context.

1) The Legal Framework in the Philippines

A. Core statute: the Dental Law

The principal law is the Philippine Dental Act of 2007 (Republic Act No. 9484), which regulates:

who may practice dentistry and allied dental professions,
licensing and registration requirements,
professional conduct and discipline, and
prohibited acts and penalties.

B. Licensing and regulation: PRC and the Board of Dentistry

Dental licensing is administered through the Professional Regulation Commission (PRC) and the Professional Regulatory Board of Dentistry (Board of Dentistry). In practice:

PRC issues professional identification cards and certificates of registration after board requirements are met.
The Board of Dentistry supervises the profession, investigates regulatory violations, and may recommend enforcement actions.

C. Criminal enforcement: prosecutor and courts

Even if a matter begins as a regulatory complaint, illegal practice is typically pursued as a criminal case through:

the Office of the City/Provincial Prosecutor (preliminary investigation), and
the courts (trial).

D. Local regulation: LGUs and business permitting

A dental clinic or dental services business usually interacts with local government through:

barangay clearances, and
city/municipal permits (business permit, mayor’s permit, zoning, sanitary requirements, etc.). An unlicensed operator may also be violating local permitting rules, which can support closure or cease-and-desist actions through LGU mechanisms.

2) What Counts as “Unlicensed Dental Practice”

A. Dentistry is broader than “tooth extraction”

Unlicensed practice is not limited to extractions. Conduct commonly treated as “practice of dentistry” includes, for example:

oral examinations, diagnoses, and treatment planning;
extractions, fillings, root canal procedures, periodontal procedures;
administering local anesthesia;
orthodontic treatment (braces installation/adjustment);
prosthodontic services when involving clinical procedures (impressions, fitting, adjustments);
surgical or invasive procedures involving the oral cavity;
prescribing or representing that one can prescribe dental drugs (even if they do not actually issue prescriptions).

Key idea: The legal risk increases when the act involves clinical judgment, invasive treatment, or holding oneself out as a dentist.

B. “Holding out” as a dentist can itself be actionable

Even without proof of an actual procedure, red flags can support a case:

advertising dental services while lacking PRC credentials,
using “DMD,” “DDS,” “Dentist,” or “Orthodontist” titles without authority,
posting clinic signage suggesting a dental practice,
collecting payment for dental treatment and presenting as licensed.

C. Allied dental roles are regulated too

The Dental Act also regulates allied professions (commonly including dental hygienists and dental technologists), each with defined scopes. Operating as if licensed in these roles—when not duly licensed—may also be unlawful. Separately, a licensed dental technologist’s lab work does not automatically authorize clinical acts on patients.

3) Who Can Be Liable

Liability can extend beyond the person holding instruments.

A. The unlicensed operator

The person who actually performs or offers clinical dental services without the required Philippine license/registration is the primary subject.

B. The clinic owner/operator or “manager”

A business owner who:

employs an unlicensed person to perform dental procedures,
allows use of the premises for illegal dental practice, or
profits from the illegal operation may face exposure depending on facts, participation, and evidence (including business records and advertising).

C. Licensed professionals who enable the practice

A licensed dentist (or other licensed professional) may be implicated if they:

lend their name/license, permit the use of their PRC ID for display,
allow unsupervised acts beyond lawful delegation, or
act as a “cover” for an illegal operator.

4) Consequences and Penalties

A. Criminal penalties under the Dental Act

Illegal practice is subject to criminal penalties, commonly involving imprisonment and/or fines. The precise penalty range depends on the specific prohibited act proven and the court’s findings.

B. Regulatory and administrative consequences

If a licensed person is involved (e.g., enabling or unethical conduct), administrative outcomes can include:

suspension or revocation of license,
fines/disciplinary sanctions,
restrictions on practice.

C. Other possible legal consequences

Depending on circumstances, additional exposure may arise under:

consumer protection principles (misrepresentation, unfair trade practices),
civil liability for damages (negligence/quasi-delict, breach of obligations, fraud),
criminal laws if injury occurs (physical injuries), deception is proven (estafa-type theories), or if counterfeit documents are used (forgery/falsification).

5) How to Identify and Verify Red Flags (Practical Indicators)

Common indicators of unlicensed practice:

refusal to show PRC professional ID or certificate of registration;
no name of a licensed dentist posted in the clinic;
receipts issued under a non-dental trade name with no dentist identified;
social media ads offering “cheap braces,” “home service extraction,” or invasive procedures without naming a licensed dentist;
procedures done in non-clinical settings (homes, salons, pop-up stalls);
use of generic claims like “certified,” “trained,” or “dental specialist” without PRC details.

Note: Absence of a displayed PRC ID is not absolute proof, but it is a strong prompt to document and report.

6) Evidence: What to Collect (Legally and Safely)

The goal is to document identity, representation, transaction, and acts.

A. Identity and representations

screenshots of advertisements (social media posts, profiles, pages);
photos of clinic signage and any posted credentials;
chats/messages where services are offered and the provider claims to be a dentist;
business cards, flyers, price lists.

B. Transaction evidence

official receipts, invoices, acknowledgments;
proof of payment (GCash, bank transfer, remittance receipts);
appointment confirmations.

C. Patient and medical evidence (if you were treated)

your clinical records (if any), consent forms, prescriptions given;
photographs of oral condition before/after (timestamped if possible);
medical/dental evaluation from a licensed dentist regarding harm caused.

D. Witness evidence

names and contact details of patients/witnesses willing to execute affidavits;
short written accounts while memories are fresh.

E. Avoid common pitfalls

Do not post accusations online (risk of defamation/cyberlibel, and it can complicate investigations).
Do not threaten or extort (“pay me or I report you”), which can backfire legally.
Preserve original files (don’t edit screenshots; keep originals).

7) Where to Report Unlicensed Dental Practice

Because enforcement can be multi-track, the most effective approach often involves parallel reporting.

A. PRC (Legal/Investigation) and the Board of Dentistry

Report to PRC and/or the Board of Dentistry for:

verification and investigative coordination,
professional regulation enforcement,
possible coordination with law enforcement for operations.

Use this route when: the primary issue is licensing/illegal practice and you have ads, receipts, or identity details.

B. Office of the City/Provincial Prosecutor (Criminal complaint)

File a criminal complaint for illegal practice of dentistry (and any related crimes) with:

the City Prosecutor (for incidents in cities) or
the Provincial Prosecutor (for municipalities).

Use this route when: you can identify the suspect and can execute a complaint-affidavit with attachments.

C. Police (PNP) for blotter and initial action

The police can:

record an incident in the blotter,
assist in evidence preservation guidance,
coordinate with prosecutors and relevant regulators for enforcement, depending on the case.

Use this route when: there is immediate risk, ongoing harm, intimidation, or urgent need to document.

D. Local Government Unit (LGU): Business permits and closure

Report to:

Business Permits and Licensing Office / Mayor’s Office,
local health/sanitation offices (as applicable),
barangay authorities for community-based enforcement and documentation.

Use this route when: there is a physical clinic operating in your locality, likely without proper permits or lawful professional supervision.

8) Step-by-Step: A Practical Reporting Path

Step 1: Write a case timeline

Create a simple chronology:

dates of consultation/treatment,
what was promised,
what was done,
how much you paid,
names used, phone numbers, and clinic address.

Step 2: Compile an evidence pack

Organize in folders:

Ads & messages,
Proof of payment,
Photos of clinic/signage,
Medical/dental findings (if harmed),
Witness details.

Step 3: Choose your filing route (or do parallel filing)

PRC/Board for regulatory action and licensing verification.
Prosecutor for criminal accountability.
LGU for immediate on-the-ground disruption (permit/closure angles).

Step 4: Execute a Complaint-Affidavit (for prosecutor)

A complaint-affidavit typically includes:

your full name and address,
the respondent’s identity details (or “John/Jane Doe” with descriptors if unknown),
narration of facts,
the harm or risk involved,
attached exhibits (marked Exhibit “A,” “B,” etc.),
a verification/jurat before a notary public.

Step 5: Attend preliminary investigation (if criminal case)

Expect:

respondent may submit a counter-affidavit,
you may be asked to reply,
prosecutor resolves whether there is probable cause to file in court.

9) Sample Templates (Adapt to Your Facts)

A. Complaint letter to PRC / Board of Dentistry (outline)

Subject: Report of Alleged Unlicensed Dental Practice

Identifying details of the suspected practitioner (name used, phone, social media, address).
Facts: what services offered/performed; dates; location; fees.
Basis for belief of unlicensed practice (no PRC ID shown; misrepresentation; ads; etc.).
Requested action: verification, investigation, appropriate enforcement/referral.
List of attached evidence (screenshots, receipts, photos, witness statements).
Your contact details and signature.

B. Complaint-Affidavit for prosecutor (outline)

I, [Name], of legal age, Filipino, residing at [Address], after being sworn, depose and state:

Respondent identity and how you encountered them.
Specific acts constituting offering/performance of dental services.
Representation as dentist and absence of proof of lawful authority.
Payments and receipts.
Harm suffered or risk created.
Evidence list (Exhibits).
Prayer for filing of appropriate charges under the Dental Act and other applicable laws. Signed and subscribed before a notary.

C. Report to LGU (outline)

Identify the establishment and exact location.
State that dental services are being offered/performed by persons who appear unlicensed.
Request inspection of business permits, sanitary clearances, and proof of professional supervision by a duly licensed dentist.

10) What Happens After You Report

A. Regulatory track outcomes

verification of credentials,
notices, investigations, possible coordination with other authorities,
administrative action if a licensed person is involved.

B. Criminal track outcomes

preliminary investigation,
filing of information in court if probable cause is found,
trial and potential conviction (or dismissal if evidence is insufficient).

C. Practical realities

Enforcement is stronger when reports include:

clear identity/location,
documentary evidence (ads, receipts, messages),
multiple complainants or corroborating witnesses,
proof that the acts were clinical/invasive (not merely a vague claim).

11) Remedies for Patients (Beyond Reporting)

If you were a patient/victim, consider these lawful remedies in addition to reporting:

Refund demands supported by receipts and misrepresentation evidence.
Civil action for damages if you suffered injury, additional medical costs, loss of income, or emotional distress, depending on proof.
Documentation of corrective treatment by a licensed dentist (to establish causation and quantify damages).

12) Risk Management: Protect Yourself While Pursuing Accountability

Keep communications factual and private to authorities.
Avoid public posting or “naming and shaming.”
Don’t alter evidence files; preserve originals.
If you feel threatened, document it and report to the police; consider protective measures available under local processes.

13) Key Takeaways

In the Philippines, dentistry is a regulated profession; offering or performing dental services without proper PRC authority is illegal.
Effective reporting combines evidence, correct venues (PRC/Board, prosecutor, LGU), and clear identification of the operator and location.
The strongest cases show representation, transaction, and clinical acts, supported by documents, screenshots, and witness statements.