PHILIPPINE COMPETITION ACT

THE PHILIPPINE COMPETITION ACT, RA 10667 Enacted in 2015, Republic Act No. 10667 or
the Philippine Competition Act (PCA) is the country’s primary competition law. It defines,
prohibits, and penalizes ANTI-COMPETITIVE PRACTICES, with the aim of enhancing
economic efficiency and PROMOTING FREE AND FAIR COMPETITION in trade, industry, and
all commercial economic activities.

WHY COMPETITION MATTERS

Competition keeps the economy working well. A competitive market is one where there are
multiple buyers and sellers. No single entity controls the price of goods or services. As such,
businesses are more attuned to consumer demand and have to innovate to make their products
different and better than the rest. For consumers - WHEN BUSINESSES COMPETE,
CONSUMERS BENEFIT THROUGH LOWER PRICES, MORE PRODUCT CHOICES, AND
BETTER-QUALITY GOODS AND SERVICES. For businesses - Businesses benefit from
competition, too. IN COMPETITIVE MARKETS, NO COMPANY BENEFITS FROM UNDUE
ADVANTAGE. This makes it easier to start and operate a new business. Competition also
enables small businesses to compete with bigger businesses on fair terms.

What businesses and entities does the PCA cover?

The PCA covers ANY PERSON OR ENTITY ENGAGED IN TRADE, INDUSTRY, AND
COMMERCE IN THE PHILIPPINES. It also applies to international trade that may impact trade,
industry, and commerce in the Philippines. Entities include GOCCs. The PCA does not apply to
collective bargaining agreements or arrangements between workers and employers, and other
such activities affecting conditions of employment.

What businesses and entities does the PCA cover?

The PCA covers ANY PERSON OR ENTITY ENGAGED IN TRADE, INDUSTRY, AND
COMMERCE IN THE PHILIPPINES. It also applies to international trade that may impact trade,
industry, and commerce in the Philippines. Entities include GOCCs. The PCA does not apply to
collective bargaining agreements or arrangements between workers and employers, and other
such activities affecting conditions of employment.

THE PHILIPPINE COMPETITION COMMISSION General duty – Ensure that BUSINESSES

COMPETE and CONSUMERS BENEFIT.
It has original and primary jurisdiction in the enforcement and regulation of all competition-
related issues.

1. Conduct inquiry, investigate, and hear and decide on cases involving violations of the
PCA, its implementing rules, and other competition laws; [Section 12 (a) and (b)]. In
connection therewith, it has: Subpoena Power [Section 12 (f)] Contempt Power [Sections
12 (e), 33, and 38] Power to inspect business premises and other properties of an entity
[Section 12 (g)] (SEPARATE LECTURE LATER)
2. Monitor and analyze the practice of competition in markets, and issue advisory opinion,
rules, and guidelines on competition matters for the effective enforcement of the PCA; a
3. Conduct, publish, and disseminate studies, reports, and other publications on
competition matters to inform and guide the industry and consumers PCA 1. Anti -
Competitive Agreements (PCA Sec. 14 IRR Rule 3, Sec. 1) 2. Abuse of Dominant
Position (PCA Sec. 15 IRR Rule 3, Sec. 2) 3. Anti-Competitive Mergers & Acquisitions
(PCA Sec. 20 IRR Rule 4)
PCC DELINEATION OF DUTIES
1. COMPETITION ENFORCEMENT OFFICE (CEO) Anti - Competitive Agreements Abuse of
Dominant Position
2. MERGERS AND ACQUISITIONS OFFICE (MAO) Anti-Competitive Mergers & Acquisitions
The CEO and the MAO directly reports to the Commission which is their INTERNAL FIREWALL
aimed at: - Preserving impartiality of adjudicating body - Safeguarding due process

WHAT ARE ANTI-COMPETITIVE AGREEMENTS?

Anti-competitive agreements are those that substantially prevent, restrict, or lessen competition.
The agreement may be any type or form of contract, arrangement, or understanding between or
among businesses to fix prices or manipulate bids. It does not matter if the said agreement is
formal or informal, explicit (i.e., written or announced) or tacit, or in written or oral (i.e., verbal)
form. IT IS ILLEGAL FOR BUSINESS RIVALS TO ACT TOGETHER IN WAYS THAT CAN
LIMIT COMPETITION OR HINDER OTHER BUSINESSES FROM ENTERING THE MARKET.

What are examples of anti-competitive agreements? What are anti-competitive agreements?

Price fixing - Businesses agree to directly or indirectly fix purchase or selling price, instead of
letting supply and demand determine the prices of goods and services.

Output limitation - Businesses agree to limit production by restricting output or setting quotas,
creating an artificial shortage in the market that subsequently drives up prices.

Bid rigging - Businesses agree to fix prices at an auction or manipulate bids, forcing buyers to
select the higher-priced “pre-selected” bid instead of the best price.

Market sharing - Businesses divide the market and claim dominance according to territory,
customer demographic, sales volume or type, creating local monopolies that deprive consumers
of choice.

Cartel - an organization formed by competitors in a specific industry, which enables them to set
prices or control levels of production. Agreements to form cartels or to collude are considered
anti-competitive agreements.

A business may become dominant in a certain industry by gaining a SIGNIFICANT SHARE IN

THE MARKET or becoming AN INDUSTRY LEADER BY VIRTUE OF YEARS IN OPERATION.
IT IS NOT ILLEGAL TO BE DOMINANT PROVIDED THEY DO NOT ABUSE THIS
DOMINANCE.

How do firms abuse their dominant position? Markets that are dominated by a single or handful
of large companies are particularly vulnerable to anti-competitive practices. Such conduct that
might indicate abuse of dominance include the following:

Predatory Pricing - A dominant firm deliberately incurs losses in the short term by selling goods
or services below the cost of its production, which can eventually force its competitors out of
business.

Price discrimination - A dominant firm sets different prices or conditions for equivalent
transactions.
Limiting production, markets, or technical development - A dominant firm restricts output or
refuses to supply, or restricts access to/use of/ development of a new technology, to the
detriment of consumers.

Exploitative behavior towards consumers, customers, or competitors - A dominant firm charges

excessive or unfair prices, or employs other unfair trading conditions.

It is not illegal to be dominant provided that a business does not take advantage of its
dominance to substantially lessen competition in the market.

STEPS TAKEN BY THE CEO or Competition Enforcement Office on the first & second kinds of
violations (Anti - Competitive Agreements & Abuse of Dominant Position)

1. Ascertain whether there are reasonable grounds to conduct FAI or full administrative
investigation upon: a) a verified complaint; b) referral by a regulatory agency; or c) by the
Commission motu proprio - Close inquiry when no violation or infringement is found - Issue
order for temporary cessation or desistance from the performance of certain acts by respondent
entity - File criminal complaints before DOJ for violations found
2. Full administrative investigation or FAI, by virtue of by a resolution to proceed issued by CEO
*Sufficient basis means the existence of such facts and circumstances that would engender a
reasonable belief that there is a violation, and that the entity investigated probably committed it
3. Adjudication by the Commission En Banc - If CEO finds sufficient basis, file Stop Order -
Close inquiry when no violation or infringement is found

WHAT IS ANTI-COMPETITIVE MERGERS & ACQUISITIONS A merger refers to the joining of

two or more entities into an existing entity or to form a new entity. Acquisition refers to the
purchase of securities or assets for the purpose of obtaining control of another entity. M&As can
benefit consumers because they may lead to businesses that operate more efficiently, enable
the transfer of technologies, broaden access to capital and increase productivity. However,
there are M&As that harm competition and can be disadvantageous to consumers.

Which M&As violate the PCA?

Not all M&As are prohibited. The PCA prevents M&As only if they substantially lessen
competition in the Philippines. For instance, M&As that create companies with dominant market
power could potentially lessen, restrict, or prevent market competition. The PCC conducts
merger review to predict a proposed M&A’s competitive impact. The review process involves
rigorous economic analysis and investigation to determine whether a transaction might harm
consumers.

There are three triggers of merger review:

1. Notification by merger parties;
2. Motu proprio or PCC’s own initiative; and
3. Third party complaints.

Notification by merger parties Currently, the PCC has set the compulsory notification thresholds
at Php 5.6 billion for the Size of Person (SoP) and Php 2.2 billion for the Size of Transaction
(SoT). Size of Transaction refers to the value of the assets or revenues of the acquired entity
Size of Person refers to the value of assets or revenues of the Ultimate Parent Entity (UPE),
including entities it controls, of at least one of the parties.
3 KINDS OF VIOLATIONS IF THRESHOLD IS MET:
1. Non- Notification - Transaction considered void Administrative fine of 1%-5% of the value of
the transaction
2. Gun-Jumping - Violation of 30-day waiting period, even if notice filed Administrative fine of
3% of the value of the transaction
3. Late Notification - Notice filed beyond 30-day notification period Administrative fine of ½ of
1%-1% of the value of the transaction, but not >PhP 2 million

In line with PCC Memorandum Circular No. 18-001 released in 2018, the thresholds for
compulsory notifications of M&As will be adjusted annually based on the nominal gross
domestic product (GDP) of the previous year.

What will the PCC do to an entity or entities found violating the PCA? The PCC is empowered to
impose fines and penalties on businesses whose conduct or activities violate the PCA, those
found to be in contempt, fail to comply with orders, or supply misleading or false information to
the PCC.

The PCA imposes four kinds of administrative penalties as follows:

1. Administrative fines for violations of Sections 14 (Anti-competitive Agreements), 15 (Abuse of
Dominant Position), 17 (Compulsory Notification), and 20 (Prohibited Mergers and Acquisitions)
2. Fines ranging from PHP50,000 to PHP2 million for failure to comply with an order of the
Commission
3. Fines of up to PHP1 million for the supply of incorrect or misleading information
4. Fines worth at least PHP50,000 for any other violation not specifically penalized under the
relevant provisions of the PCA This schedule of fines shall be increased by the Commission
every five years to maintain their real value from the time they were set.

ONLY THE COURT OF APPEALS AND THE SUPREME COURT MAY ISSUE A TEMPORARY
RESTRAINING ORDER OR INJUNCTION AGAINST THE PCC IN THE EXERCISE OF ITS
DUTIES AND FUNCTIONS.

MAO’S OR MERGERS AND ACQUISITIONS OFFICE MERGER REVIEW PROCEDURE

Initiated either by notification from parties within 30 days from signing of definitive agreements
relating to the M&A, or by the Commission motu proprio. a. Sufficiency of the notification within
15 calendar days; If insufficient, return notification b. Phase 1 Review 30 calendar days c.
Phase 2 Review 60 calendar days Prohibit Approve unconditionally Approve with conditions
Deemed approved.

MAO INVESTIGATION PROCEDURE 1 Complaint 2 MAO Monitoring Investigation if there are

reasonable grounds send notice to Explain Not less than 15 calendar days otherwise Close
investigation MOA files complaint with Commission for Adjudication/Decision

For purposes of applying for search and inspection orders, these are the sources of their
information

SEARCH & INSPECTION ORDERS COMPETITION ENFORCEMENT OFFICE (CEO) Cartels

Testimonies of officers and employees
E-mails; Text messages; Calendar entries; Meeting notes; Price lists; Price quotations;
Conspiracy code words; Telephone records; Appointment books; Expense account records;
Board presentations.

MERGERS AND ACQUISITIONS OFFICE (MAO) Anti-Competitive Mergers & Acquisitions

Testimonies of officers and employees; E-mails and text messages; Meeting notes and
minutes ; Board presentations; All other preparatory documents.

SEARCH & INSPECTION ORDERS COMPETITION ENFORCEMENT OFFICE (CEO) Cartels

Testimonies of officers and employees E-mails Text messages Calendar entries Meeting notes
Price lists

What are dawn raids?

“Dawn raids” or Unannounced raids Recognized in other jurisdictions as an effective tool for
competition law enforcement.
 A.M. NO. 19-08-06-SC RULE ON ADMINISTRATIVE SEARCH AND INSPECTION
UNDER THE PHILIPPINE COMPETITION ACT (R.A. NO. 10667)

Legal Basis:

Article VIII, Section 5, par. 5, 1987 Constitution

Re:Rule-making power of the supreme court

“Promulgate rules concerning the protection and enforcement of constitutional rights, pleading,
practice, and procedure in all courts, the admission to the practice of law, the integrated bar,
and legal assistance to the underprivileged. Such rules shall provide a simplified and
inexpensive procedure for the speedy disposition of cases, shall be uniform for all courts of the
same grade, and shall not diminish, increase, or modify substantive rights. Rules of procedure
of special courts and quasi-judicial bodies shall remain effective unless disapproved by the
Supreme Court.”

Article III, Section 2 , 1987 Constitution

Right against unreasonable searches and seizure

“Section 2. The right of the people to be secure in their persons, houses, papers, and effects
against unreasonable searches and seizures of whatever nature and for any purpose shall be
inviolable, and no search warrant or warrant of arrest shall issue except upon probable cause to
be determined personally by the judge after examination under oath or affirmation of the
complainant and the witnesses he may produce, and particularly describing the place to be
searched and the persons or things to be seized.”

SECTION 12(G), R.A. NO. 10667 OR THE PHILIPPINE COMPETITION ACT (PCA)
“Upon order of the court, undertake inspections of business premises and other offices, land
and vehicles, as used by the entity, where it reasonably suspects that relevant books, tax
records, or other documents which relate to any matter relevant to the investigation are kept, in
order to prevent the removal, concealment, tampering with, or destruction of the books, records
or other documents;

SEC. 2 - THE INSPECTION ORDER

- An order in writing issued in the name of the Republic of the Philippines signed by a judge
- UPON APPLICATION OF THE PCC, THROUGH ITS DULY AUTHORIZED OFFICER
- Authorizing the PCC and any law enforcement agency that may be DEPUTIZED BY THE PCC
to assist in the execution of the order
- To search and inspect business premises and other offices, land and vehicles
- For information to be examined, copied, photographed, recorded, or printed, in order to
prevent the removal, concealment, tampering with, or destruction of such information.

Who may apply for an inspection order?

1. The PCC through its duly authorized officer
2. Any law enforcement agency that may be DEPUTIZED BY THE PCC to assist in the
execution of the order
3. Designated officers from: a) Competition Enforcement Office CEO b) Mergers and
Acquisitions Office MAO
Application for an inspection order with the court
Court hears the application ex parte
Court issues an inspection order
Conduct of inspection of premises
Filing of return

SEC. 3 - WHERE APPLICATION IS FILED

- Enforceable Nationwide Special Commercial Courts in Quezon City, Manila, Makati, Pasig,
Cebu City, Iloilo City, Davao City and Cagayan De Oro City
- Within territorial jurisdiction Special Commercial Courts in the judicial regions where the place
to be inspected is located shall have concurrent jurisdiction
- Multiple locations Quezon City, Manila, Makati, Pasig, Cebu City, Iloilo City, Davao City and
Cagayan De Oro City + judicial regions where the place to be inspected is located

SEC 4. APPLICATION
Contents:
1. The subject of the administrative investigation;
2. The premises, other offices, land or vehicles, as used by the entity, sought to be searched or
inspected; and
3. The information sought to be examined, copied, photographed, recorded, or printed, and their
relevance and necessity to the investigation.

Inspection may be conducted during the early stages of the investigation.

In the application, the description of the investigation need not be too detailed as to provide the
entities involved or the exact modus or scheme SECTOR + PRESUMED VIOLATION UNDER
THE PCA IS ENOUGH
Example:
a) minutes of the meeting from years 2013 to 2015
b) emails between Mr. X and Mr. Y from years 2015 to 2016.

What are the information sought to examined?

Books, tax records, documents, papers, accounts, letters, photographs, objects or tangible
things, databases and means of accessing information contained in such databases, and
electronically stored information as defined in the rules of procedure of the PCC, which relate to
any matter relevant to the administrative investigation

SEC. 5 - EXAMINATION OF APPLICANT

THE COURT MUST EXAMINE IN THE FORM OF SEARCHING QUESTIONS AND
ANSWERS, IN WRITING AND UNDER OATH OR AFFIRMATION, THE APPLICANT AND THE
WITNESSES HE OR SHE MAY PRODUCE ON:

1. Acts personally known to them; or

Facts based on:
(1) the applicant’s or witnesses’ training and/or experience;
(2) authentic records;
(3) verifiable data; or
(4) economic analysis.
 2. Training and/or Experience of the Applicant:

The purpose of an inspection is to gather information relating to a suspected violation of the

PCA, its IRR and other competition laws Thus, it is not necessary that the facts be known to the
applicant or the witnesses based on personal knowledge.

It would be sufficient if the applicant or witness can attest to the facts based on the applicant’s
or witnesses’ training and/or experience.

HOW SHOULD THE JUDGE CONSIDER ECONOMIC ANALYSIS?

Competition law is a combination of law and economics Competition law violations usually
detected through:
a) market surveillance
b) market studies analyzing the competitive conditions and the behavior of the players in that
market

Where the economic analysis reveals indicators of anti-competitive conduct or practice, an

investigation may be pursued to gather evidence.

HEARING CONDUCTED BY THE JUDGE:

The Application must be ACTED UPON WITHIN 24 HOURS from filing of verified application
Ex-parte
Held in the chambers of the judge
Confidential
FAILURE OF THE JUDGE TO ACT WITHIN THE 24-HOUR PERIOD SHALL RESULT TO
ADMINISTRATIVE SANCTIONS.

ELEMENT OF SURPRISE
The hearing on the application is done ex parte and the proceedings are kept confidential
THE MOST IMPORTANT FEATURE OF DAWN RAIDS IS THE ELEMENT OF SURPRISE
Entity has no opportunity to conceal or destroy information

SEC. 6 – ISSUANCE OF INSPECTION ORDER

The Inspection Order shall be issued if the court finds a reasonable ground to suspect that:
1. The information relates to any matter relevant to the investigation;
2. The issuance of the order is necessary to prevent the removal, concealment, tampering with,
or destruction of the books, records, or other documents to be inspected; and
3. The information is kept, found, stored, or accessible at the premises indicated in the
application.

Sec. 7 – EFFECTIVE PERIOD OF INSPECTION ORDER

Effective for the LENGTH OF TIME AS DETERMINED BY THE COURT, which shall NOT
EXCEED FOURTEEN (14) DAYS FROM ITS ISSUANCE.

The court may, upon exparte motion, extend the effectivity of an inspection order for a PERIOD
NOT EXCEEDING 14 DAYS from the expiration of the original period.

Extensions may be sought when:

a)the inspection cannot be carried out within the 14-day period
b) the entity refuses to allow PCC, deputies or agents despite valid service of the court order In
such instances, the PCC may seal or secure the area and equipment, gadgets or devices Seek
relief with the court by INSTITUTING CONTEMPT PROCEEDINGS Pending the decision on the
contempt case, the period of effectivity of the inspection order may be extended until the court
resolves the matter NO LIMIT ON THE NUMBER OF EXTENSIONS THAT MAY BE ALLOWED
BY THE COURT BASED ON ITS REASONABLE DISCRETION

SEC. 8 – WHEN ORDER IS SERVED

Served in the presence of a duly designated officer of the court During BUSINESS HOURS OF
THE PREMISES, OR AT ANY TIME ON ANY DAY, as may be determined by the court for
COMPELLING REASONS stated in the application

SEC. 9 - PERSONS WHOSE PRESENCE ARE REQUIRED DURING INSPECTION

-Person designated by the entity:
- Compliance officer
- any officer of the entity designated or appointed by the entity to represent the latter on
governmental regulatory matters or any compliance officer for any regulatory body (e.g. General
Compliance Officer)
- Legal counsel Any unreasonable delay, failure, or refusal to designate a representative by the
entity shall not prevent the PCC from implementing the inspection order

SEC. 10 – MANNER OF INSPECTION

Persons designated by the entity have the following duties:
a) Cooperate and render assistance to PCC in order to facilitate the search and inspection.
b) Provide PCC with all reasonable facilities and assistance for the conduct of the inspection.
c) Disclose the location of the information, access codes, or passwords
d) Certify faithful reproduction of the copies, photographs, recordings, or printouts made by PCC
officers, deputies or agents.

The following persons are required to certify the information inspected by the PCC:
1. By person designated by entity; or
2. Highest ranking official or employee present if the entity fails to designate a person

Effect of Certification:
The Information shall be admissible as evidence for the purpose of the administrative
proceedings Refusal to certify PCC may institute contempt proceedings the PCC may seal or
secure the area and equipment, gadgets or devices until the person certifies such copies,
photographs, recordings, or printouts.

PLAIN VIEW –
OTHER INFORMATION FOUND IN PLAIN VIEW MAY BE EXAMINED, COPIED,
PHOTOGRAPHED, RECORDED, OR PRINTED IF:
1) THE PRESENCE OF PCC OFFICERS, DEPUTIES OR AGENTS IN THE PREMISES IS
PURSUANT TO AN INSPECTION ORDER;
2) THE DISCOVERY OF THE INFORMATION IN PLAIN VIEW IS INADVERTENTLY MADE IN
THE COURSE OF IMPLEMENTING THE INSPECTION ORDER; AND
3) IT IS IMMEDIATELY APPARENT TO THE OFFICER THAT THE ITEM HE OBSERVES MAY
BE EVIDENCE OF A VIOLATION OF THE PCA, ITS IMPLEMENTING RULES, OR OTHER
COMPETITION LAWS.
What are the powers of the PCC during inspection?
1. Enter, search and inspect the premises indicated in the order;
2. Examine, copy, photograph, record, or print information described in the order;
3. Examine and copy electronically stored information, databases, and means of accessing
information contained in such databases by copying the information, whether through forensic
imaging or other means of copying, photographing or recording the electronically stored
information or by printing out its contents;
4. Require electronically stored information and databases be produced in a form that is visible
and legible, and may be copied, photographed, recorded, or printed out;
5. Ask explanations on facts or documents relating to the subject and purpose of the inspection
and record the answers;
6. Secure or seal the area and equipment gadgets or devices where the information is located
or stored;
7. Attach to the information a tag or label warning all persons from tampering with them, until the
examination, copying, photographing, recording, or printing is completed, but in no case beyond
the effectivity of the inspection order; and
8. Examine, copy, photograph, record, or print other information believed, on reasonable
grounds, to be evidence of a violation of the PCA, its IRR, or other competition laws.

Securing and sealing the premises where the information is located is necessary when:
1. during extended inspections (e.g. inspections which last more than a single day)
2. to avoid the loss, removal, or otherwise destruction of the information
3. if the entity refuses to allow the examination, copying, photographing, recording of information
4. The area and equipment, gadgets or devices shall remain sealed until the entity complies
with the inspection order.
5. If entity refuses to certify faithful reproduction of the copies

SEC. 12 – RETURN
Within three (3) days from the enforcement of the Inspection Order or after the expiration of its
period, whichever comes first, the PCC officer shall make a verified report to the issuing court A
return is a report to the court that issued the inspection order informing it on the results of the
execution of the order The return shall be accompanied by the following:
1. A list of information copied, photographed, recorded, or printed
2. Affidavit of the PCC Officer

Contents of the PCC Officer’s Affidavit:

1. The date and time of examination and copying of the documents
2. The particulars of the documents, electronically stored information, databases, or means of
accessing information
3. The manner by which the documents was copied.

DUTY OF THE ISSUING JUDGE: ASCERTAIN IF THE RETURN HAS BEEN MADE, AND IF
NONE, TO SUMMON THE PCC OFFICER AND REQUIRE HIM TO EXPLAIN WHY NO
RETURN WAS MADE

SEC. 13 - WHEN AN INSPECTION ORDER IS IMPROPERLY ISSUED OR IMPLEMENTED

Before a return is filed, the person or entity whose premises were inspected may file a written
motion WITH THE ISSUING COURT TO QUASH THE INSPECTION ORDER ON THE
GROUND THAT IT WAS IMPROPERLY ISSUED OR IMPLEMENTED. The motion shall be
RESOLVED IN A SUMMARY HEARING by the issuing court after due notice to the PCC.
SEC. 15 – EFFECT OF VIOLATION
Contempt proceedings under Rule 71 of the Rules of Court for non-compliance with the
inspection order or any provision of these Rules
1. Unreasonably delays, fails, or refuses to designate a representative
2. Tampers with, breaks or removes the seal affixed
3. Destroys or deletes files or information
4. Destroys or tampers with the information subject of the inspection order
5. Interferes with the implementation of the inspection order

SEC. 16 - INSPECTION ORDER NOT A BAR TO OTHER MEASURES

The PCC is not precluded from exercising its powers under existing laws and rules when it
applies for an inspection order

THE PCC IS LIKEWISE NOT PREVENTED FROM REQUESTING LAW ENFORCEMENT

AGENCIES TO ASSIST IN THE APPLICATION OF A SEPARATE SEARCH WARRANT FOR
CRIMINAL VIOLATIONS OF THE PCA.

SEC. 17 – LIMITED USE

The information collected pursuant to the inspection order shall be used ONLY IN
ADMINISTRATIVE PROCEEDINGS FOR VIOLATIONS UNDER THE PHILIPPINE
COMPETITION ACT AND OTHER COMPETITION LAWS.