I. Overview

Recurring payments are now everywhere in the Philippines: streaming services, apps, online tools, insurance, loans, telco “value-added services,” auto-debit for bills, and more. These are convenient when authorized — and a nightmare when they continue without your consent or after you’ve tried to cancel.

This article explains, in a Philippine legal and practical context:

What “unauthorized recurring payments” are
The laws and regulations that apply
Your rights against banks, e-wallets, and merchants
How to stop the charges and seek a refund
When you may need to go to regulators, courts, or law enforcement

This is general information, not a substitute for advice from a Philippine lawyer who has reviewed your specific documents and facts.

II. What Is a Recurring Payment?

A recurring payment is an arrangement where a merchant or service provider repeatedly charges your:

Credit card or debit card
Bank account (auto-debit arrangement or ADA)
E-wallet / payment account (e.g., auto-renew for subscriptions, billers)
Telco account (postpaid plan add-ons, content subscriptions, etc.)

Common examples:

Monthly subscriptions (video/music streaming, online tools, gyms, software)
Installment plans (e-commerce, gadgets, insurance premiums)
Auto-debit for loans, utilities, tuition, or insurance

These are lawful only if you consented, and the merchant stays within the terms you agreed to.

III. When Is a Recurring Payment “Unauthorized”?

In the Philippine setting, a recurring charge is usually considered unauthorized if any of the following is true:

No consent at all
- You never signed anything, clicked “subscribe,” or gave card/account details for that merchant.
- You never agreed to a free trial that converts to a paid subscription.
Consent was obtained by fraud or deception
- You were told it was a one-time charge, but fine print said recurring.
- The merchant hid or buried the auto-renew clause.
- Someone tricked you into typing a one-time password (OTP) or giving card details, which were then used to set up recurring charges.
Use of stolen or compromised credentials
- Your card is lost, stolen, skimmed, or cloned, and the thief sets up recurring payments.
- A hacker/phishing scam gets your card or e-wallet details and uses them for subscriptions.
Charges go beyond what was authorized
- Amount is higher than agreed, or frequency is more often.
- Merchant is different from the one you authorized (e.g., your data was sold or misused).
- You agreed only to a trial unless you expressly confirm renewal, but they charge anyway.
You already revoked your consent — but they keep charging
- You cancelled via email, app, or website, but they still bill you.
- You revoked an auto-debit authority with the bank, yet debits continue.

In contrast, a recurring payment is not “unauthorized” in the strict sense if:

You genuinely agreed to a subscription with automatic renewal;
The charges match what you agreed to; and
You simply forgot to cancel on time.

In those cases, you still may have rights to cancel going forward, but the past charges may not be refundable unless the merchant’s own policy or law says otherwise (especially in cases of unfair or deceptive terms).

IV. Key Legal Foundations in the Philippine Context

Several laws and regulations indirectly or directly cover unauthorized recurring payments:

Civil Code of the Philippines
- Governs contracts, consent, and obligations.
- Consent obtained by fraud, mistake, intimidation, or undue influence can make a contract voidable.
- Payments made without obligation can be recovered (solutio indebiti).
- Principles on agency/mandate apply to auto-debit authorities (you authorize the bank to pay a third party).
Consumer Act of the Philippines (Republic Act No. 7394)
- Protects consumers from misrepresentation, deceptive, and unfair sales practices.
- Requires clear, truthful information on goods/services.
- Can apply where a merchant hides auto-renewal or misleads you about recurring charges.
Data Privacy Act (Republic Act No. 10173)
- Protects personal and financial data.
- Using your card or account data for recurring payments beyond what you consented to may be unauthorized processing of personal information.
- You can complain to the National Privacy Commission (NPC) if your financial data was misused.
Electronic Commerce Act (Republic Act No. 8792)
- Recognizes the validity of electronic contracts, signatures, and records.
- Click-through/online subscriptions are valid contracts if consent is properly obtained.
Access Devices Regulation Act (Republic Act No. 8484)
- Covers credit cards, ATM cards, and access devices.
- Criminalizes fraudulent use of access devices and related schemes.
- Can apply when someone uses your card without consent to set up recurring payments.
New Payment System Law (Republic Act No. 11127) and Bangko Sentral Regulations
- BSP regulates banks, e-money issuers, and payment system operators.
- They must implement controls against unauthorized transactions, set dispute mechanisms, and protect consumers.
Special sectoral regulations
- Telco / NTC rules for mobile content and value-added services.
- Insurance Commission for insurance premiums.
- SEC for investment/financing companies.
- DTI for general consumer complaints and unfair trade practices.

V. Types of Recurring Payment Arrangements and How They Work Legally

1. Credit card recurring payments

You give your card details (or save card on file) and agree to recurring billing.
Legally, this is:
- A contract between you and the merchant, plus
- An access device transaction under RA 8484, and
- An arrangement governed by card issuer’s terms and card network rules (Visa, Mastercard, etc.).
The bank/card issuer must have:
- Systems to verify your transactions,
- A process for you to dispute unauthorized or erroneous charges (“chargeback” or reversal).

2. Debit card recurring payments

Similar to credit cards, but money is taken directly from your deposit account.
Banks must have safeguards and dispute processes because these are electronic fund transfers.

3. Auto-Debit Arrangements (ADAs) on deposit accounts

You sign a specific auto-debit authority with your bank, authorizing it to debit your account regularly for a particular payee (loan, insurance, utilities).
Legally, this is like a mandate/agency you give the bank.
Important:
- There should be a written or electronic authority identifying the payee, amount, and frequency.
- You generally have the right to revoke this mandate, subject to any conditions clearly agreed upon (e.g., as part of loan security).

4. E-wallet and payment app recurring charges

Subscriptions and auto-pay features tied to GCash, Maya, GrabPay, etc.
Governed by:
- The user agreement you accept in the app,
- BSP rules on e-money and electronic payments.
Still requires your clear consent before recurring charges start.

5. Telco and value-added services

Postpaid subscriptions, ringtones, games, content subscriptions, “load-based” auto-renew products.
Regulated by telco laws and NTC rules, plus general consumer and contract laws.
Many disputes arise where users claim they never subscribed or didn’t realize it was recurring.

6. Loan amortizations, insurance premiums, and others

Auto-debits or card charges used as mode of payment for long-term contracts.
Cancelling the recurring payment does not cancel the underlying loan or policy, but you may switch to another mode of payment if allowed by the contract.

VI. Your Legal Rights When Facing Unauthorized Recurring Payments

1. Right to revoke consent or authority

You normally have the right to:

Cancel a subscription or service with reasonable notice, unless a fixed-term contract clearly limits this.
Revoke an auto-debit authority with your bank or payment provider.
Withdraw consent to use your personal/financial data for further transactions.

While the other party can claim damages if you breach a fixed-term contract, they cannot insist on continuously charging you after you’ve clearly revoked your authority to charge a specific card/account.

2. Right against fraudulent and deceptive practices

Under the Consumer Act and Civil Code:

Merchants cannot rely on hidden or deceptive fine print to justify charges you never truly agreed to.
Misrepresentation can make a contract voidable and open the door to damages.

3. Right to dispute unauthorized electronic transactions

Banks and payment providers, as regulated entities, must:

Accept your dispute or complaint about unauthorized transactions.
Investigate within a reasonable period.
Follow BSP rules on liability allocation between customer and financial institution.

In many frameworks, if you promptly report the unauthorized activity and did not act with gross negligence, the institution may bear the loss (or at least part of it) for clearly unauthorized transactions.

4. Right to privacy and data protection

If your data was:

Used beyond the purpose you consented to (e.g. your card details were shared or sold for subscriptions),
Or used without your consent for recurring billing,

you can complain to the National Privacy Commission (NPC) for violations of the Data Privacy Act.

5. Right to redress through regulators and courts

You can:

File complaints with BSP (for banks, e-wallets, card issuers),
DTI (for consumer goods/services merchants),
NTC (for telco-related recurring charges),
NPC (for data misuse),
SEC or Insurance Commission (for entities under their supervision),
File a case in court for refunds, damages, or injunction (to stop ongoing debits),
Use Small Claims Court for lower amounts (no lawyer required up to certain thresholds, subject to current rules).

VII. Duties and Responsibilities of the Key Players

A. Banks, card issuers, and payment providers

They are expected to:

Maintain robust security and authentication (e.g., OTP, 3-D Secure, transaction alerts).
Keep records showing your authorization, especially for recurring card-on-file setups and ADAs.
Provide clear dispute mechanisms and timelines.
Block or suspend your card/account when you report loss, theft, or suspected fraud.
Implement internal rules for chargebacks, reversals, and provisional credits where applicable.

If they ignore your dispute or unreasonably refuse to assist when you promptly report, you may escalate to the BSP and potentially claim damages.

B. Merchants and service providers

They should:

Clearly disclose that the arrangement is recurring and the amount/frequency.
Provide an easy cancellation mechanism (in-app, website, email, or hotline).
Send notice of renewal or price changes where reasonably expected.
Stop charging promptly after you cancel or withdraw consent.
Keep proof that you opted in to the recurring arrangement.

C. You, as the consumer

Your duties include:

Reviewing terms and conditions where reasonably possible (yes, even the boring bits).
Monitoring your statements and transaction history.
Promptly reporting suspicious charges.
Acting with reasonable care to protect your card, PIN, and OTPs (e.g., not sharing them with anyone, not sending them via chat).

Your behavior can affect how liability is allocated — gross negligence (like freely handing around your OTP) can weaken your claim.

VIII. Practical Steps to Stop Unauthorized Recurring Payments

Below is a step-by-step approach, whether the payment hits a card, bank account, e-wallet, or telco bill.

Step 1: Identify the source and pattern

Check which account is being debited:
- Credit card? Debit card? Specific bank account? E-wallet? Postpaid bill?
Note:
- Merchant name as it appears on the statement (it may be abbreviated).
- Amount and frequency.
- When the charges started.

Step 2: Secure your payment instrument

If you suspect fraud or compromise:

Immediately contact your bank/e-wallet provider/card issuer:
- Report the transaction as unauthorized.
- Request blocking of:
  - The card (for credit/debit), and/or
  - Further debits to that merchant, and/or
  - Entire account access for e-wallets if necessary.
Change your passwords and PINs for:
- Online banking,
- E-wallets,
- Email accounts (since OTPs go there),
- App stores (Google Play / Apple ID).

Early reporting is crucial. The longer you wait, the easier it is for institutions to argue you were negligent.

Step 3: Dispute the transaction in writing

Even if you called the hotline, follow up in writing:

Use the bank/app’s official dispute form if available.
If not, send an email or letter stating:
- Your full name and account number.
- The specific transactions (date, amount, merchant).
- That you did not authorize these recurring payments OR that you cancelled earlier and have proof.
- That you are formally disputing the transactions.
- Request:
  - Reversal/refund, and
  - Blocking of future charges.

Keep copies, screenshots, reference numbers, and delivery receipts.

Step 4: Contact the merchant or service provider

In parallel:

If you know who the merchant is, contact them directly via:
- Their website or in-app support,
- Email,
- Official social channels (as backup).

Tell them:

You did not authorize the recurring charges; or
You are cancelling with immediate effect; and
You demand they stop billing and refund unauthorized charges.

Take screenshots/printouts of cancellation confirmations or any response.

Special case: App store subscriptions For subscriptions via Google Play or Apple App Store, you normally must cancel through the app store (Subscriptions section). Telling the merchant directly may not be enough if the platform handles billing.

Step 5: Revoke auto-debit authority (if applicable)

If it’s an auto-debit arrangement with a bank:

Write to the bank requesting:
- Immediate revocation/cancellation of your auto-debit authority for Merchant X or for that purpose.
- Written confirmation of the effectivity date.
Check if:
- The ADA is a condition of a loan or similar contract. Cancelling the ADA may still stop the debits, but you remain liable for the loan. You may have to shift to another mode of payment to avoid default.

Step 6: Monitor and escalate

Regularly check if the charges have stopped.
If the bank or merchant:
- Ignores you,
- Rejects your dispute without real investigation, or
- Continues charging,

you can escalate:

To the internal Customer Assistance / Complaints Unit of the bank or merchant.
Then, to regulators (BSP, DTI, NPC, NTC, etc.) depending on who oversees the entity.
If the amount is large or the conduct is serious, consult a lawyer about civil or criminal action.

IX. Special Situations

1. “Free trial” that silently converts to paid

Legally, this often hinges on whether:
- The terms clearly disclosed the auto-renewal and price.
- You had a reasonable chance to cancel before the first billing.
If the merchant hid the auto-renewal or made cancellation unreasonably difficult, you can argue it is:
- A deceptive/unfair practice, and
- The charges are invalid or at least partly refundable.

2. Foreign or cross-border merchants

Many digital subscriptions are with foreign entities.
Your card issuer or payment provider is usually your main enforcement point through chargeback and disputes.
The foreign merchant’s terms may stipulate foreign law and jurisdiction, but Philippine consumer and card rules can still apply through your local bank.

3. Charges after death of the account holder

Recurring payments should stop once the bank is informed and accounts are settled.
The estate can dispute post-death charges and seek refunds.

4. Corporate cards or company accounts

Company policies may govern what happens if recurring charges are set up without authority.
There may be internal disciplinary and recovery rules in addition to external legal remedies.

X. Remedies: Getting Your Money Back and Holding Parties Accountable

Depending on the circumstances, you may pursue:

Administrative remedies
- Complaints to BSP, DTI, NPC, NTC, SEC, Insurance Commission, etc.
- These can lead to orders to refund, correct systems, or penalize regulated entities.
Civil remedies
- Demanding refunds (restitution for payments not due).
- Claiming damages for financial loss, inconvenience, or credit impact.
- Asking courts for injunctions to stop ongoing debits.
- Using Small Claims Court for lower amounts (more accessible, simplified procedure).
Criminal remedies
- If someone fraudulently used your card or credentials, you may file complaints for:
  - Violations of RA 8484 (Access Devices Law),
  - Estafa under the Revised Penal Code,
  - Possible cybercrime if done through hacking or online fraud.
- Criminal cases focus on punishing the offender; restitution may be ordered but is not guaranteed.

XI. Evidence and Documentation: What You Should Keep

To strengthen your position:

Bank and e-wallet statements showing the recurring charges.
Screenshots of app subscriptions, settings, and cancellation steps.
Emails and chat logs with merchants and banks.
Copies of signed ADAs or subscription agreements (if any).
Police reports or incident reports (for clear fraud).
Notes of call dates, times, names of representatives, and reference numbers.

These are vital whether you’re dealing with a bank’s complaints unit, a regulator, or a court.

XII. Preventive Tips: How to Avoid Unauthorized Recurring Payments

Use virtual or limited-use cards for online subscriptions where available.
Avoid saving your main card details on every website — use trusted payment gateways.
Regularly review:
- Credit card statements,
- Bank passbooks/online histories,
- E-wallet activity logs,
- App store subscriptions.
Never share:
- OTPs,
- CVV or full card numbers,
- Online banking passwords, even with someone claiming to be from your “bank.”
Keep a list of all legitimate subscriptions and when they renew.
Immediately lock, freeze, or block your card/e-wallet if you lose your phone or card, or if you see suspicious notifications.
When cancelling a subscription, always:
- Take screenshots of confirmation screens,
- Check the next statement to ensure charges have stopped.

XIII. Final Thoughts

In the Philippine context, stopping unauthorized recurring payments is a mix of:

Understanding that no one can lawfully charge you on a recurring basis without valid consent,
Knowing your rights to revoke consent, dispute charges, and seek refunds, and
Acting quickly and methodically in notifying banks and merchants, documenting everything, and escalating when necessary.

If the amounts involved are significant, or the situation is complex (business accounts, cross-border entities, unclear contracts), consider consulting a Filipino lawyer to review your documents and handle formal demands or complaints on your behalf.