Ignatius Michael D. Ingles
Partner

Ignatius Michael D. Ingles is regarded as the leading sports lawyer in the Philippines. A licensed attorney in the Philippines and New York, he heads the sports law practice of ILC Law. He represents professional and national athletes in issues of non-payables, taxation, doping, immigration, eligibility, endorsements, brand protection, family matters and employment. He spearheaded the Rights Protection Program during the 2023 FIBA World Cup in the Philippines and has advised national sports associations, leagues and brands.

He has also shaped sports law education and scholarship in the Philippines. As a full-time professor at the Ateneo Law School, he created the country’s first dedicated sports law certificate program in the Philippines. He authored Laws for Sports and the Sporty, and has also written extensively for both local and international publications, including Batas Sportiva, Rappler, Spin.ph, the Ateneo Law Journal, the International     Encyclopaedia of Laws, the Marquette Sports Law Review, and the Georgetown Law Journal.

Tiffany Kim R. Maglunog
Junior Partner

Tiffany Kim R. Maglunog focuses on corporate and property-related matters, with a growing emphasis on the regulatory landscape of the gaming industry. Her practice includes advising clients on corporate structuring, compliance requirements, and transactional matters across a range of sectors, including manufacturing, education, utilities, and electronic gaming.

She serves as corporate secretary and/or director for various entities operating within and beyond Special Economic Zones, giving her practical experience in corporate governance and regulatory compliance in highly regulated industries.

In the gaming sector, Kim has assisted clients in establishing corporate vehicles and navigating licensing and accreditation requirements before the Philippine Amusement and Gaming Corporation (PAGCOR). Her work supports investors in aligning their business structures with applicable regulatory frameworks and operational standards.

Daphne Marie M. Gomez
Associate

Daphne Marie M. Gomez is a Philippine-based lawyer in the sports law practice of The Law Firm of Ingles Laurel Calderon. She assists athlete clients with matters such as contract review, immigration, brand protection and liaising with their National Sports Associations (NSAs). She works with other sports stakeholders such as NSAs and sports agents in reviewing and drafting corporate documents and contracts. She recently served as the Head of Legal for 2025 FIFA Futsal Women’s World Cup Local Organising Committee, overseeing legal support for event execution including stakeholder negotiations, contract reviews, visa and work permit processing, and crisis mitigation and management.

Overview of the Philippine Gambling and Gaming Legal Landscape

To understand gambling and gaming in the Philippines, we must start with the core government agency that regulates all matters in this industry – the Philippine Amusement and Gaming Corporation (PAGCOR). Established by Presidential Decree No. 1869, as amended by Republic Act No. 9487, PAGCOR is a government-owned and controlled corporation that acts as the central authority to operate and regulate games of chance.

PAGCOR’s objectives are two-fold: first, to consolidate the right and authority to operate and conduct games of chance into a single entity controlled and supervised by the Philippine Government, and second, to establish and operate clubs and casinos for amusement and recreation, including sports gaming pools and such other forms of amusement and recreation including games of chance, allowable by law.¹Section 1, Presidential Decree No. 1869, as amended by Republic Act No. 9487.

In its operations, PAGCOR aims to generate additional government revenue for infrastructure development and socio-civic programs, and aims to boost tourism by developing integrated entertainment and recreational facilities. Lastly, PAGCOR aims to minimize, if not completely eliminate, the illegal practices, corruption, and other social evils associated with unregulated gambling operations.2

Legality or Illegality of Gambling in the Philippines

As a product of more than 300 years of colonialism and a country steeped in Roman Catholic tradition, the Philippines has a rather complicated relationship with gambling. The Revised Penal Code (RPC), the general criminal law of the Philippines passed at the height of the American colonial era, outright banned any form of gambling. But in the post-independence years and with a shifting view towards new revenue streams, the Philippine government has chipped away at this outright ban with special laws allowing certain gambling activities, as long as these are conducted pursuant to a valid legislative franchise, governmental authority, license, or permit.

Historically, gambling had been seen as a Crime Against Public Morals,²Chapter I, Title VI, Book II, Revised Penal Code. and has been regulated to “repress an evil that undermines the social, moral and economic growth of the nation”.³People v. Fermin Punto, G.R. No. 46170, 20 September 1939. It was seen as having the “effect of causing, dishonesty, fraud and deceit”, whereby individuals have neglected their business, integrity, and family.⁴U.S. v. Prudencio Salaveria, G.R. No. L-13678, 12 November 1918

One illegal gambling act under the Revised Penal Code is to directly or indirectly participate in any game of monte, jueteng or any form of lottery, policy, banking, or percentage game, dog races, or any other game of scheme the result of which depends wholly or chiefly upon chance or hazard.⁵Art. 195 (1), Revised Penal Code, as amended by Commonwealth Act 235. Thus, games where the result depends wholly or chiefly upon skills are not considered illegal gambling.⁶U.S. v. Isidro Hilario, G.R. No. L-6941, 06 March 1913. However, being mere spectators or bystanders was not considered indirect participation that would hold them liable, since mere presence in a gambling house was not among the offenses listed in the RPC.⁷U.S. v. Santiago Palma, G.R. No. 2188, 05 May 1905.

The RPC criminalized participation in games of chances where wagers consisting of money, or articles of value or representative of value are made or when there was exploitation or use of any other mechanical invention or contrivance to determine by chance the loser or winner of money or any object or representative of value.⁸Ibid. In these activities, not only were the direct participants liable, but those who enabled these activities were likewise liable. For example, a person who knowingly permits these activities to occur in any building, vessel or other means of transportation owned or controlled by him also commits an illegal act.⁹Art. 195 (2), Revised Penal Code. Similarly, the maintainer, conductor, or banker in a game of jueteng or similar games were also held liable.¹⁰Art. 195 (3), Revised Penal Code. It was even illegal to possess any lottery list, paper or other matter containing letters, figures, signs or symbols which pertain to or are in any manner used in the game of jueteng or any similar game which has taken place or is about to take place.¹¹Art. 195 (4), Revised Penal Code.

However, with the creation of PAGCOR, certain games of chances are now allowed. PAGCOR was established to strictly manage, regulate, supervise and control activities which involve games of chance. Thus, these games are allowed, provided they are properly registered with and the appropriate licenses are issued by PAGCOR.¹²Sections 1 and 11, Presidential Decree No. 1869, as amended by Republic Act No. 9487.

Another illegal gambling act under the RPC is to import into the Philippines, sell, or distribute any lottery ticket or advertisement. “Lottery” in this instance refers to a “scheme for the distribution of prizes by chance among persons who have paid, or agreed to pay, a valuable consideration for the chance to obtain a prize”.¹³U.S. v. Hilario Filart, G.R. No. L-10263, 13 March 1915.

However, with the creation of Philippine Charity Sweepstakes Office (PCSO), lottery is now permitted, albeit regulated. PCSO is authorized to hold and conduct charity sweepstakes races, lotteries, and other similar activities,¹⁴Section 1 (A), Republic Act No. 1169, as amended by Batas Pambansa Blg. 42 and Presidential Decree No. 1157. and its Board is authorized to promulgate regulations to regulate the conduct of such activities.

Under the RPC, participation in horse racing had also been illegal, including betting on such races, and maintaining or employing a totalizer or other device or scheme for betting on horse races, or otherwise realizing income therefrom. Any person, whether natural or juridical, who knowingly tolerated the commission of horse betting was likewise liable.¹⁵Article 198, Revised Penal Code.

However, horse race is now permitted, provided it is license by the Games and Amusements Board (GAB). With Presidential Decree No. 420 and subsequently, Presidential Decree No. 871, horse racing was placed under the jurisdiction of the GAB. GAB has the power and duty to supervise and regulate professional games in the Philippines,¹⁶Section 1, Presidential Decree No. 871. including the power to issue, suspend or revoke licenses or permits to conduct professional games.¹⁷Section 2 (e) and (f) , Presidential Decree No. 871.

The RPC also provides that it is illegal to participate in, by either betting or organizing fights, cockfights at any place other than a licensed cockpit. To get said license, the Cockfighting Law of 1974 provides that city and municipal mayors are authorized to issue licenses for the operation and maintenance of cockpits.¹⁸Section 6, Presidential Decree No. 449.

Sports betting used to be illegal under Art. 197 of the RPC, but PAGCOR, under its regulatory powers, has now allowed sports betting, as long as operators secure prior authority from PAGCOR. While sports betting is now allowed, activities which destroy the integrity and honesty of sports competitions—such as game-fixing, point-shaving, and game machinations—remain criminalized under Presidential Decree No. 483.

In sum, though not absolutely prohibited, only gaming operations authorized and supervised by the State, through PAGCOR, PCSO, GAB, and local government units, may legally operate within the country, subject to applicable laws and regulatory requirements.

Trends and Developments in the Field of Gambling and Gaming Laws in the Philippines

Three major trends or developments in the gambling and gaming scene in the Philippines are (1) the Supreme Court decision in the case of Joseller M. Guiao v. PAGCOR, (¹⁹Ibid.) game-fixing in Philippine basketball, and (3) the controversy on Philippine Offshore Gaming Operators (POGOs).

Joseller M. Guiao v PAGCOR

Decided in 2024, Joseller M. Guiao v. PAGCOR, PSCO, and the Office of the President is a landmark case for sports and gaming law in the Philippines. In said case, the Supreme Court order PAGCOR to account and remit all 5% of its gross income per year from 1993 up to the present, and PCSO was ordered to account and remit the 30% representing the charity fund of the proceeds of six sweepstakes or lottery draws per year (including lotto draws) from 2006 onwards to the PSC.

The case stemmed from an interpretation of Section 26 of the Philippine Sports Commission (PSC) Act which mandates PAGCOR to remit 5% of its gross income to the PSC to improve sports funding in the Philippines. The PCSO is also required to remit 30% of the proceeds of six sweepstakes or lottery draws per year to the PSC as part of the NSDF.²⁰Section 26, Republic Act No. 6847.

Professional basketball coach and then-member of the House of Representatives Joseller M. Guiao, more widely known as Yeng Guiao, questioned why PAGCOR and PSC had not been remitting the full amounts under the law.

PAGCOR claimed that it was not mandated to remit the entire 5% of its gross income, arguing that any remittance to the PSC was subject to deductions for the payment of PAGCOR’s 5% franchise tax owed to the national government and the 50% share of the national government under its charter.

PCSO claimed its contributions to the PSC should only be sourced from sweepstake draws and not from other PCSO lottery games, arguing that its lottery games did not fall within the definition of “lottery draws” under the law.

The Supreme Court found that the PAGCOR’s obligation was to remit all 5% of its gross income to the PSC, as the law made no qualifications or deductions.

In finding against the PCSO, the Supreme Court explained that “lottery” is defined as extending to “all schemes for the distribution of prizes by chance, such as policy playing, gift exhibitions, prize, concerts, raffles at fairs, and various forms of gambling”. A lottery is said to have three essential elements: consideration, prize and chance – all of which are applied to the PCSO’s “lotto draws” as “the payment of the prize of the lotto ticket is the consideration for the chance to win the prize offered in the lotto draw”.

Game-Fixing Scandal in Professional Basketball

The second most popular professional basketball league in the Philippines, the Maharlika Pilipinas Basketball League (MPBL), has recently been confronted with sports betting-related and game-fixing scandals.

In 2021, the Department of Justice found probable cause to file charges against seventeen individuals involved in alleged match-fixing operations that rocked the league in mid-2019.²¹Gerry Ramos, Game-fixing raps filed against Soccsksargen owner, players, Chinese ‘mastermind’. 12 November 2019, https://www.spin.ph/basketball/mpbl-files-charges-of-game-fixing-against-top-officials-players-ofsoccsksargen- a793-20191112, last accessed 20 May 2026.

In 2024, the MPBL announced that it has banned forty-seven players and officials, as its founder, boxing legend Manny Pacquiao, has identified game-fixing a major issue for league.²²From the Wires, MPBL bans 47 players, officials for ‘game-fixing,’ lifts limit on ex-pros, 06 February 2024, https://www.spin.ph/basketball/mpbl-lifts-limit-on-pro-players-welcomes-new-teams-from-abra-pangasinan- a1373-20240206, last accessed 20 May 2026.

To this day, the MPBL game-fixing scandal has yet to arrive at a conclusion.

The POGO Controversy

Philippine Offshore Gaming Operators (POGOs) are entities that provide and participate in offshore gaming services, such as by providing the game, taking bets, or paying the winnings.²³Section 4 (c), Title I, Rules and Regulations for Philippine Offshore Gaming Operations, Philippine Amusement and Gaming Corporation.

Offshore Gaming Operators refer to PAGCOR-licensed operators that offer online games of chance exclusively to offshore authorized players, excluding Filipinos abroad, who have registered and established an online gaming account with said operator. It has three components, which are:

1. A prize, consisting of money or something of value;

A player who:

2. Being located outside of the Philippines and not a Filipino citizen, enters the game remotely through electronic communication network;
3. Gives or undertakes to give monetary payment or payment of valuable consideration to enter in the course of, or for, the game; and
4. The winning is decided by chance.²⁴Section 4 (b), Title I, Rules and Regulations for Philippine Offshore Gaming Operations, Philippine Amusement and Gaming Corporation.

Around the time of the Covid-19 lockdown, Philippine media began linking POGOs to other, more severe criminal activities, such as human trafficking, kidnapping and illegal detention, torture, scams, forced labor and other activities related to organized crime.

The National Bureau of Investigation reported that from November 2019 to March 2023, POGO-related crimes had reached 113 cases, of which 58% are human trafficking cases.²⁵Hana Bordey, NBI data showed majority of POGO-related crimes are human trafficking, 15 May 2023, https://www.gmanetwork.com/news/topstories/nation/870074/nbi-data-shows-majority- of-pogo-related-crimes-are-human-trafficking-cases-gatchalian/story, last accessed 20 May 2026.

The Philippine National Police also reported that from January 2017 to 23 January 2023, there were at least 102 POGO-related, crimes victimizing around ²⁶Presidential Communications Office, PBBM signs into law Anti- POGO Act of 2025, institutionalizing ban on POGOs, 29 October 2025, https://pco.gov.ph/news_releases/pbbm-signs-into- law-anti-pogo-act-of-2025-institutionalizing-ban-on-pogos/, last accessed 20 May 2026.6 individuals.²⁷Id.

The Bureau of Internal Revenue also reported that 34.2 billion Philippine Pesos-worth of gross gaming revenues were underreported by POGOs from January to August 2022 alone, which resulted in unpaid taxes amounting to 1.7 billion Philippine Pesos.²⁸Id.

In June 2023, the National Capital Region Police Office and the Philippine National Police-Anti Cybercrime Group conducted a raid of a POGO-hub in Las Piñas, rescuing 2,714 workers of different nationalities from Asia and Africa, allegedly forced to work at an illegal POGO.²⁹Id.

By 2024, it was reported that there were around 200 POGO businesses in the Philippines, but only about 60 had the proper license to operate.³⁰Hermes Joy Tunac, POGO hub in Pampanga caught in illegal activities including sex trafficking, kidnapping, 09 June 2024, https://www.gmanetwork.com/news/topstories/regions/ 909522/pogo-hub-in-pampanga-caught-in-illegal-activities-including-sex-trafficking-kidnapping/story/, last accessed 20 May 2026.

Around June 2024, the Presidential Anti-Organized Crime Commission raided a POGO hub in Pampanga, a 10-hectare compound owned by Lucky South 99, and revealed that individuals were being kept in the compound, subject to physical torturing. The same POGO hub was used as a nest for sex trafficking, and authorities revealed that they obtained a video of two foreign females dancing naked and were being sold online.³¹Id.

In his 2024 State of the Nation Address, President Ferdinand Marcos, Jr. acknowledged the need to outright ban POGOs in the Philippines due to crimes linked to POGO hubs, such as trafficking and torture. On 05 November 2024, he signed Executive Order No. 74, mandating all POGOs to cease operations by the end of the year.³²Luisa Cabato, SOP for Pogo ban implementation signed by various gov’t agencies, 22 April 2026, https://globalnation.inquirer.net/319407/sop-for-pogo-ban-implementation-signed-byvarious- govt-agencies, last accessed 20 May 2026

On 23 October 2025, the President signed the Anti- POGO Act of 2025 into law, institutionalizing an outright ban on POGOs.

Booming Online Industry

Despite recent developments such as game-fixing issues and the ban on POGOs, data shows that the Philippine gaming industry is booming. In 2025, it saw a 6.39% growth in total revenues, primarily due to the popularity of digital betting and online gaming. The Philippine gaming industry generated 396.14 billion Philippine Pesos in gross gaming revenues (GGR) in 2025, 201.12 billion of which came from electronic and online gaming segment, overtaking casinos as the largest GGR contributor.³³PAGCOR, Ph Gross Gaming Revenues up 6.39% to Php 396.14B in 2025, 16 April 2026, https://www.pagcor.ph/headlines/ph-gross-gaming-revenues-up-6.39percent-to-php396.14bin- 2025.html, last accessed 20 May 2026. The industry has gotten so big that the Central Bank of the Philippines has stepped in and directed e-wallet providers to remove direct gambling access from their platforms because of rising concerns on gambling addiction, fraud, and financial harm.³⁴Memorandum No. M-2025-029, Bangko Sentral ng Pilipinas.

As the industry continues to expand through aggressive marketing, celebrity influence, and financial technology integration, regulators and society face the challenge of balancing economic benefits with the need to protect consumers from the social and financial risks associated with increasingly accessible gambling platforms.