By Sophia T. Magallona, JD1
With the rise of online communication platforms, online dating has become an increasingly common method for Filipinos to form romantic relationships; however, this growing reliance on virtual interactions has also given rise to legal and social challenges that are unique to the online environment. Since most online relationships begin between individuals who are complete strangers, they are vulnerable to various forms of misconduct, including—but not limited to—fraud, estafa, identity theft, psychological or sexual abuse, and other cyber-related offenses. Many Filipinos remain unaware of the legal remedies available to address these issues. A prevailing misconception is that legal remedies are limited or inapplicable when the aggrieved party only knows the offender through an online platform. This research aims to address this gap in public awareness by examining the legal remedies available under Philippine laws to individuals who become victims of wrongful acts in the context of online romance. The principal objective of this study is to identify and analyze the legal recourse available to such individuals, with a particular focus on existing jurisprudence. This study will adopt a doctrinal research methodology, involving a thorough examination and interpretation of existing legal statutes and principles relevant to online relationships, with a primary focus on current Philippine laws that provide protection to victims and impose liability for unlawful conduct occurring in digital contexts. In addition, the study will conduct a comprehensive review of relevant jurisprudence from Supreme Court decisions involving parties who initially met online or whose relationship developed through online communication in order to develop a clear and structured understanding of the legal remedies available within the Philippines.
INTRODUCTION
Online dating is a form of initiating romantic or sexual involvements with other people using websites to create profiles and get matched with others to find anything from casual dates to serious relationships. In a study from 2015, it showed that around one-third of new romantic relationships during that time in the United States start online, meaning online dating has become a common way for people to meet. (Toma, 2015). A recent statistical study from 2024 show that the Philippines had also been strongly engaging in platforms that allow for online relationships. The survey showed that Tinder, an online dating application, was the most popular among Filipinos aged 16 to 34 years old while Dating.com was more popular for Filipinos above 55 years old. (Balita, 2024).
Facebook is another prevalent social media site that is used for online dating among users. This was boosted further last 2019 when Meta launched a feature called ‘Facebook Dating’. Meta added this feature where users can make a dating profile within their account to make it easier to find romance and forming relationships through the application itself (Sharp, 2019). Another statistical study in 2024 by Bosze, A. revealed that the Philippines ranked 6th globally in the amount of Facebook users, identifying around 87.7 million users in the country.
With the rise of online communication platforms, online dating has become an increasingly common method for Filipinos to form romantic relationships; however, this growing reliance on virtual interactions has also given rise to legal and social challenges that are unique to the online environment.
For instance, in a news article last February 13, 2024 published by Manila Bulletin, a 56-year old single mother lost P260,000 to a conman posing as a potential love interest. Another instance of a cyber crime in relation to online love is sexual exploitation of two minors from Cebu City where a random stranger befriended two minor girls and elicited lewd performances from them through video call as reported by Inquirer last February 2024.
UNICEF had also published in their website revealing that in year 2021 alone, around two million Filipino children were subjects of online sexual exploitation where they experienced grooming and offers of gifts in exchange for sexual acts. Some children were even threatened by online strangers to engage in such acts.
Since most online relationships begin between individuals who are complete strangers, they are vulnerable to various forms of misconduct, including—but not limited to—fraud, estafa, identity theft, psychological or sexual abuse, and other cyber-related offenses. In another news article published last February 11, 2024 by PhilStar Global, the Philippine National Police (PNP) data showed that there were around 19,472 cybercrimes reported in the year 2023 – which would be an average of 53 cyber-related offenses per day.
With the increasing cases and reports, it is evident that there is a slight improvement in the awareness and courage of Filipinos to seek proper justice for offenses done against them. However, the Cybercrime Investigation and Coordinating Center (CICC) have stated that “although the number of cybercrime complaints it received in 2024 tripled from the prior year, the number of reports it is receiving is still considered low to obtain the “real picture” of the situation.”.
As found in report and statistical study by UNICEF last March 2025 on Filipino youth active online, around 86% of the respondents have encountered issues like inappropriate content and online abuse that makes them feel unsafe on the internet. 57% of them revealed further that those issues have happened multiple times. Most of them do something when they face online abuse, with about 56% blocking or reporting the person on the app or website. But only around 3% report it to the police or help hotlines. About 19% choose to handle it on their own and don’t tell anyone. Even though online harassment is common, many young people still don’t know where to go for help.
In relation to cyberstalking, from a study by Smith (2023) conducted in the United Kingdom, it was found that approximately 86% of cyberstalking victims did not personally report their experience to law authorities. The said study revealed that the most common reasons for not reporting included: (1) not knowing their experience was criminal in nature, (2) dealing with it another way, and (3) thinking the police would not do anything for them or would not be helpful for their situation.
Clearly, there is a large disparity between victims who experience cybercrime and victims who report their experiences to proper authorities for various reasons ranging from unawareness to disbelief of the law that could protect them.
While laws exist to punish cyber crimes commonly experienced in online relationships, there are practical challenges such that offenders may hide behind anonymous accounts complicating identification of suspects (Respicio, 2024). This may contribute to the prevailing misconception that legal remedies are limited or inapplicable when the aggrieved party only knows the offender through an online platform.
OBJECTIVES
This research aims to address the existing gap in public awareness concerning legal remedies available to individuals in the Philippines who become victim of cybercrimes arising from online romance. With the growing number of digital platforms as a mode for fostering dating relationships, cases of deceit, financial or sexual exploitation, and even identity theft have become increasingly common. However, still, many victims, remain unaware of the legal recourse they can seek.
The principal objective of this study is to identify and analyze the legal recourse available to these individuals under Philippine law, with a particular focus on applicable statutory provisions from codal provisions, special laws and existing jurisprudence regarding cybercrime.
In addition, this study seeks to inform the public of the specific steps they may take even in their own ‘barangays’, such as filing a report with the barangay authorities or local police, securing sworn affidavits, and initiating preliminary investigations. By exploring both formal judicial and quasi-judicial remedies, this research aims to empower victims of online romance scams to seek the redress and justice they deserve.
METHODOLOGY
This study will adopt a qualitative research methodology entailing identification and brief analysis of existing legal statutes and regulations relevant to online relationships. The primary focus will be on Philippine laws that provide protection to individuals who fall victim to wrongful acts from online dating interactions. The study will explore how these laws establish legal liability for unlawful conduct committed through online platforms.
In order to cater extra understanding of the legal remedies available, the study will also discuss an overview of relevant Supreme Court jurisprudence where available, particularly decisions where relationships between parties originated or significantly developed through online communication. This analysis of jurisprudence will aim to identify how courts have interpreted and applied legal provisions in cases involving digital romance.
For a more focused approach, this study will highlight three common issues arising from online relationships. To each issue, legal remedies will be identified, ranging from codal provisions to special laws, along with steps that must be taken and to which proper authority victims must seek.
DISCUSSION
Among problems arising from online relationships, three issues have been prevalent in the Philippines, namely: (1) Financial Scams and Catfishing, (2) Cyber Harassment or Cyberstalking, and (3) Sexual Exploitation and Non-consensual Sharing of Intimate Images. For the purposes of this study, discussion will focus on these three issues identified.
Financial Scams and Catfishing
A research study from 2023 defines financial scams in online relationships as when a person uses online platforms to create a romantic relationship where they can defraud others for monetary gain. Such cybercrime usually leaves victims heartbroken while also facing financial ruin (Bilz et al., 2023). On the other hand, ‘Catfishing’ has been defined as a form of deceiving others online by using an identity that is either not legitimate or someone else’s; usually to trap victims into engaging in online relationships with them (Ryan & Taylor, 2024).
Catfishing and financial scams usually go hand in hand in online relationships. The perpetrator will use a fake identity to gain the victim’s trust to obtain monetary gain from them utilizing the benefits of being in a “relationship” with the victim.
Last February 2025, the National Bureau of Investigation (NBI) conducted a major raid on a in Makati City. They uncovering a large-scale “love scam” hub. The scammers used convincing fake profiles to attract their victims who they start engaging with online and thereafter begin to ‘date’ them virtually. Once they gained the victims’ trust, they would manipulate them emotionally and lead them to fraudulent cryptocurrency investments or other kinds of monetary scams (Philstar, 2025).
In 2024, Central Visayas authorities noticed an increase of romance scams, affecting Filipino victims. The NBI – Region 7 (NBI-7) reported at least six formal complaints. However, they emphasized that the real number is likely much higher due to underreporting. Many victims are reluctant to report because of embarrassment based on the circumstances. One reported case shows a victim who was defrauded of ₱23 million. At the beginning of the ‘online relationship’, the scammer using a fake profile would usually shower the victim with affection, compliments, and declarations of love within a short period such as expressing love or intent to marry. As the relationship develops, the scammer starts fabricating financial emergencies such as “a parcel supposedly held by customs that needs money for release.” (Cebu Daily News, 2024).
Fortunately, in Philippine laws, there are several provisions that victims can rest upon. The Revised Penal Code of the Philippines penalizes Estafa (Swindling) under Article 315 which defines the crime as when an offender through false pretenses, fraudulent representation, or abusing trust and confidence induces another to part with his property (or money) and that the victim suffers loss or damage as a result.
In a news article from October 2022, a woman was arrested and charged with Estafa when she posed as a member of the U.S. Army developing an online relationship with the victim and thereafter asked for money from the victim in the guise of being a lover with promises of settling down with the victim in the Philippines (Torres-Tupas, 2022). In this case, the false representation of being a U.S. Army officer and the fake romantic gestures constitute deliberate deceit, fulfilling the elements required for Estafa.
Beyond the Revised Penal Code, the victim may also invoke protection under a special penal statute, Republic Act No. 10175, also known as the Cybercrime Prevention Act of 2012. This law enhances legal remedies available to individuals victimized through the use of online platforms. Section 4(b)(3) of said special law criminalizes computer-related identity theft, including unauthorized use of another person’s identity (may be fictitious) for obtaining money, services, or any other personal benefit. Section 5 also penalizes the attempt, aiding, or abetting in the commission of cybercrimes, making accomplices equally liable under the law. Additionally, Section 6 of the same law stipulates that “crimes committed through Information and Communications Technology (ICT) shall be subject to one degree higher penalty than that imposed under the Revised Penal Code or special laws” (Cybercrime Prevention Act, 2012)
Courts have upheld the view that the use of digital or online modes aggravate offenses, given the potential for wider reach, anonymity, and difficulty of detection (People v. Agbulos, G.R. No. 240167, August 14, 2019). Victims of such schemes are encouraged to pursue remedies under both the Revised Penal Code and R.A. 10175 to ensure maximum legal protection and penalty imposition.
Cyber Harassment or Cyberstalking
Harassment refers to any unsolicited behavior that either offends, intimidates, or threatens a person. It may be verbal, physical, visual, or online and can occur in various settings, physically or digitally. On the other hand, stalking has been defined as a repeated pattern of unwanted attention without justification that causes safety concerns and fear for the victim. The ‘stalker’ is usually a stranger to the victim (Mapue, 2012). As a form of harassment, cyber stalking has been defined as the use of the Internet through any of the modes available to ‘stalk’ another person. (Stevens et al., 2020)
According to Kapersky (2024), to recognize falling victim to such cybercrime requires awareness of patterns of persistent, unwanted communication through online platforms, unauthorized access or attempts to access personal accounts, or that the offender seems to track or know the victim’s whereabouts suspiciously. Such incidents are common, with approximately 23% of online daters reporting cyberstalking experiences.
In a post shared anonymously on the r/LawPH subreddit (online forum) in July 2024, a Filipino man shared his experience of being cyberstalked by his ex-girlfriend after the end of their online relationship. He noted that throughout their time together, he had provided her with financial support through frequent money transfers. When they broke up, the woman allegedly started to harass and stalk him through various social media platforms and sending him unsolicited messages via GCash, and even made uninvited visits to his residence. The anonymous poster documented these using screenshots seeking legal counsel. He considered filing a complaint under the Cybercrime Prevention Act of 2012, as well as invoking provisions of the Revised Penal Code related to unjust vexation under Article 287.
Although the Cybercrime Prevention Act of 2012 (R.A. 10175) is the primary legislation addressing offenses committed online as discussed in the previous issue, it does not explicitly define “cyberstalking”. However, it covers behaviors such as cyber harassment, cyber threats (linked to Article 282 of the Revised Penal Code), and unjust vexation or coercion via electronic means which closely relates to the concept of cyberstalking.
For women specifically, Republic Act No. 9262, known as the Anti-Violence Against Women and Their Children Act, addresses psychological violence that includes harassment conducted through technology by current or former intimate partners. Section 5(h) specifically penalizes harassment through texts, calls, or online communication that causes emotional suffering to women or their children. (Anti-Violence Against Women and Their Children Act, 2004).
Lastly, another avenue for people to rest upon is the Safe Spaces Act (Republic Act No. 11313), or the “Bawal Bastos Law” which punishes online harassment like stalking, threats, and repeated unwanted contact. Section 12 of said Act covers various forms of online harassment such as catcalling, sending lewd images, and stalking via online platforms. This law provides extra protection for victims of cyber harassment in public (or semi-public) online spaces as it applies even when the offender and victim have no prior romantic involvement (Safe Spaces Act, 2019).
Sexual Exploitation and Non-consensual Sharing of Intimate Images
Online sexual abuse occurs in several ways through online platforms or applications. Forms of online sexual abuse include sending unwarranted explicit pictures, demanding or eliciting such pictures, and threats to spread shared intimate images for the purposes of manipulating and abusing an online partner. These abuses takes advantage of the trust developed in online relationships, where victims may not fully understand the risks associated with sharing personal and intimate information to a person they met online.
Unfortunately, there is a prevalence of young children and teenagers in the online setting and they are the common targets of perpetrators of online sexual exploitation due to their naivete. Many victims experience ‘grooming’ where abusers form trust with minors to exploit and manipulate them; minors’ intimate images are used for blackmail (UNICEF, 2021).
A 2024 study by Johns et al. noted a rise in cases of online sexual exploitation correlating with increased internet and smartphone use among the youth. The accessibility of dating applications and social media platforms has allowed interactions that evolve into exploitative relationships. Victims may experience grooming, emotional manipulation, and threats of “revenge porn” or non-consensual sharing of intimate images, which are used to intimidate them.
During the COVID-19 pandemic, there was a reported surge in online interactions through online dating platforms. Save the Children Philippines (2020) noted a significant rise in complaints related to online sexual abuse among teenagers using social media and dating applications. Moreover, law enforcement agencies have reported cases where offenders make use of online wallets to solicit sexual favors.
In early 2025, authorities arrested individuals involved in manipulating and coercing their online dating partners into sharing explicit content by threatening to expose their intimate pictures in public forums (Philippine National Police, 2025).
Philippine laws offer several remedies for addressing online sexual abuse in dating relationships such as the Cybercrime Prevention Act of 2012 (RA 10175) as discussed which punishes unauthorized sharing of intimate images.
In AAA v. BBB (G.R. No. 212448), the Supreme Court ruled that abuse and threats sent through digital messages still constitute psychological violence under RA 9262 (AAA v. BBB, G.R. No. 212448, January 11, 2018). This ruling confirmed that threats to release intimate images and coercive online behavior like sexual exploitation by an online romantic partner are still punishable offenses.
As the common target of this issue is children and women, the Anti-Violence Against Women and Their Children Act (RA 9262) is particularly relevant. While R.A. 9262 was enacted before the emergence of social media and online abuse, it still applies to online sexual exploitation, especially in cases involving emotional, psychological, or sexual abuse conducted through the use of online platforms. Section 3(d) describes sexual violence to include any sexual act committed against a woman or her child that is non-consensual, coercive, or forced which being pressured or manipulated to send explicit content personally or online. Fortunately, Section 3(e) expands the law’s coverage to include a “dating relationship,” which it defines as a romantic or intimate relationship that exists over time, regardless of whether the parties live together (Anti-Violence Against Women and Their Children Act, 2004). This expansion allows protection over relationships that happen online.
Some Cases and Existing Jurisprudence
Recent Philippine Supreme Court rulings recognizes the increasing crimes related to online sexual abuse, scams, and harassment, which are important in understanding legal protections and enforcement challenges in online dating relationships. These cases clarify the application of the Cybercrime Prevention Act of 2012 (RA 10175) and other related laws in addressing offenses done online.
In Catan y Masangkay v. People (G.R. No. 261156), the Court affirmed the conviction of a defendant who extorted money from a minor by threatening to expose her private photos online. The case notably confirmed that extortion committed through Information and Communication Technology (ICT) constitutes robbery under the law, with penalties aggravated by the use of digital means. The ruling in this case highlights how the integration of ICT in crimes such as extortion, which are common in abusive online dating scenarios where intimate images are weaponized, have harsher and aggravated penalties (Catan y Masangkay v. People, G.R. No. 261156, August 23, 2023).
In the case of People v. Eul Vincent O. Rodriguez (G.R. No. 263603), it involved the exploitation and trafficking of minors through Facebook and Skype. The Supreme Court ruled that digital evidence, including chat logs and videos, is admissible and valid in cybercrime cases (People v. Eul Vincent O. Rodriguez, G.R. No. 263603, October 09, 2023). This ruling established an important precedent for prosecuting online sexual exploitation, allowing effective use electronic or digital evidence in court proceedings. For victims in online dating contexts, this enhances the possibility of holding perpetrators accountable even when offenses occur entirely online, which addresses the challenging gap between online abuse and legal remedy.
In People v. Tria (G.R. No. 255583), the Court upheld conviction of the defendant who threatened to upload nude photos of his ex-girlfriend on Facebook (People v. Tria, G.R. No. 255583, August 02, 2023). The case reinforced the principle that the use of ICT in committing such offense results to an aggravated penalty, as stipulated under the Cybercrime Prevention Act. This ruling is directly applicable to cases of revenge porn or non-consensual sharing of intimate images often observed after an online relationship ends.
Collectively, these cases show how Philippine courts are integrating traditional criminal statutes, including the Revised Penal Code, to the Cybercrime Prevention Act and other laws addressing the evolving online venue of abuse. The aggravated penalties and recognition of digital or electronic evidence expands protection of victims in online dating relationships where perpetrators use ICT to to manipulate, harass, or exploit partners.
Pursuing Legal Action & Gathering Evidence
In recent years, cases involving parties who have never met in person but developed relationships solely through online platforms have increased significantly in the Philippines. These interactions would eventually result to online dating scams, cyberstalking, or online sexual abuse. Due to the absence of physical contact, such cases are frequently prosecuted under laws and statutes that cater to cases of cybercrime as discussed.
A key challenge in prosecuting cybercrimes rooted in online-based relationships is the nature of the evidence. Because the parties never meet physically, the case largely depends on digital or electronic documentation like chat logs, screenshots, transaction receipts, voice notes, and email threads. Consequently, victims are encouraged to preserve all communications and record any threats or financial transfers to strengthen their case (Philippine National Police Anti-Cybercrime Group, 2023).
After collecting evidence, victims may file a complaint-affidavit with the National Bureau of Investigation (NBI) Cybercrime Division or the Philippine National Police Anti-Cybercrime Group (PNP-ACG), both of which specialize in digital forensics and cybercrime investigation. These institutions can trace IP addresses, authenticate metadata, and recover deleted messages. For formal legal action, victims may file a complaint affidavit with the Office of the City or Provincial Prosecutor to initiate preliminary investigation.
Once a formal complaint is lodged, the case progresses to investigation and potential prosecution if there is enough admissible evidence. Victims are advised to fully cooperate with prosecutors and be prepared to testify. In parallel to criminal prosecution, civil actions for damages may also be pursued, especially in cases involving reputational and psychological harm from non-consensual sharing of intimate images.
Reports can also be initiated in local barangay authorities. Although barangays do not have jurisdiction over criminal prosecution, they serve as a first point of contact, especially for documentation, initial protective measures, or referrals. Victims may file a report directly to the Barangay Violence Against Women (VAW) Desk, where they are asked to provide a sworn statement and digital evidence (Philippine Commission on Women, 2023). However, it is important to note that cybercrimes involving abuse, exploitation, or threats do not require barangay mediation, and officials are expected to refer such cases directly to law enforcement agencies in accordance with R.A. 9262, which allows for immediate issuance of Barangay Protection Orders (BPOs) for cases involving violence against women and children (including abuse committed through electronic means).
In addition, victims may seek assistance from the Department of Justice (DOJ) Office of Cybercrime, which provides both investigatory support and technical help for the removal of harmful online content. Complaints can be submitted online via the DOJ cybercrime portal or via email, especially for cases involving data privacy violations, grooming, or revenge porn (Department of Justice (DOJ) Office of Cybercrime, 2022).
CONCLUSION
The evolution of human relationships through online means, while convenient, has exposed individuals to a wide range of risks that traditional legal frameworks were not initially designed to address. In the Philippines, the merging of romance and technology has facilitated emerging forms of criminal behavior like online financial scams, catfishing, cyber harassment, stalking, and sexual exploitation. These cyber offenses takes advantage of the anonymity of online platforms which creates challenges for law enforcement and application.
Through a review of current jurisprudence, existing statutes, and real-life cases, this study illustrates the response of Philippine law to cybercrimes committed in online relationships. The Revised Penal Code, when read in relation to special penal laws such as R.A. 10175 (Cybercrime Prevention Act of 2012), R.A. 9262 (Anti-Violence Against Women and Their Children Act), and R.A. 11313 (Safe Spaces Act), provides comprehensive legal recourse for victims of online-relationship abuse. Landmark Supreme Court decisions discussed like People v. Tria, Catan y Masangkay v. People, and People v. Rodriguez have established and reinforced the legal doctrine that ICT-based crimes result to higher penalties, which affirms the Philippine judiciary’s adaptability to our evolving world.
The study also highlights the importance of public awareness and preparedness. The prevalence of underreported cases reflects societal stigma, lack of digital literacy, and limited access to cybercrime response modes. Victims, often isolated or emotionally manipulated, may hesitate to seek help. Therefore, this research supports the demand for stronger preventive strategies like more effective digital literacy campaigns, support systems, and more proactive surveillance by cybercrime agencies such as the NBI Cybercrime Division and PNP Anti-Cybercrime Group.
Ultimately, while Philippine law has made significant progress in addressing cyber offenses within online relationships, the dynamic nature of digital platforms requires continuous legal reform and improved enforcement infrastructure. The goal must not only be to punish offenders of cybercrime but also to establish a safer and more informed online environment to make it a genuine avenue for human connection.
RECOMMENDATIONS
To enhance the Philippines’ response to the prevalent issues arising from online relationships, several strategic measures are recommended.
First, the government must prioritize strengthening the enforcement of existing legal frameworks such as the Cybercrime Prevention Act (R.A. 10175) for it provides a solid basis for prosecution. However, it requires an improved implementation and wider information dissemination to ensure both victims and law enforcers fully understand the provisions and applications. Additionally, effective public education initiatives are important to inform citizens about the risks that could arise from online relationships and the legal remedies available (Zeyrus Johns et al., 2024). Coordinated efforts between government agencies and the private sector like technology companies and social media platforms, should be enhanced to make a safer online environment and reduce victimization (Department of Justice, 2024).
Second, law enforcement agencies such as the Philippine National Police (PNP) and the National Bureau of Investigation (NBI) must improve operational efficiency in addressing these cybercrimes. The public should be made more aware of the existince of the e-Government (eGov) reporting system which facilitates easier and convenient reporting of incidents, thereby increasing case detection and monitoring capabilities (Philippine National Police Anti-Cybercrime Group, 2023). The successful deployment of artificial intelligence and digital forensics tools, as evidenced by recent NBI operations targeting romance scams, should be expanded and further supported (National Bureau of Investigation, 2025). Moreover, continuous specialized training for investigators on the evolving modus operandi of cybercriminals is crucial to keep up with the sophisticated use of technology in cybercrime (Stevens et al., 2020).
Finally, raising public awareness is foundational in the prevention strategy. Educational campaigns tailored to diverse demographic groups should be implemented through various media channels, community programs, and online platforms. Increasing public knowledge not only empowers potential victims but also helps deter perpetrators by heightening the perceived risks of detection and legal consequences (Bilz et al., 2023). The publication of successful law enforcement actions and court rulings related to online abuses can further serve as an effective deterrent by demonstrating the state’s commitment to combating such offenses (SunStar Manila, 2025). Collaborative outreach efforts involving social media companies are also recommended to ensure the timely dissemination of warnings and support resources (Kaspersky, 2024).
Through these combined efforts in legal enforcement, technological innovation, and public education, the Philippines can significantly improve its capacity to protect citizens from the harms associated with online romantic relationships and digital abuse.
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