SYLLABUS

Consumer Protection Law and Competition Law Compliance

AY 2020-2021
Atty. Leah Jose-Sebastian

COURSE DESCRIPTION

This is a 2-subject course that focuses on the legal framework in the Philippines
for consumer protection against (a) unsafe and sub-standard products and services, and
(b) illegal business conduct that harms competition and consumers.

Illegal business conduct includes (i) unconscionable sales acts and practices, and
(ii) anti-competitive behavior of persons and entities engaged in any trade, industry and
commerce in the Philippines.

Part A. Consumer Protection Law

1. We will study the principles, laws and regulations which apply to transactions
involving products and services, as well as their sale, advertising and
promotion.

2. Topics in this elective course are related to core Law subjects such as
Constitutional Law, Corporation Law, Obligations and Contracts, Civil Law
and Criminal Law. Students are thus able to apply the relevant provisions of
these laws in the assessment, handling and resolution of consumer issues and
disputes.

Part B. Competition Law Compliance

1. We will study the concepts and principles in competition law, and the
Philippine Competition Act (RA 10667), its Implementing Rules and
Regulations and other competition-related laws.

2. We will utilize a practical approach, applying theory (i.e., Competition-related

laws, regulations and State policies) to real-world transactions involving
agreements and conduct affecting competition and consumers.

3. We will consider:

(a) local and global business realities (i.e., challenges and restrictions that
confront business organizations);
(b) current decisions and actions taken by Government authorities within and
outside the Philippines against conduct deemed anti-competitive; and
(c) how we can enable competition law compliance.

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 4. Topics in this elective course are related to core Law subjects such as
Constitutional Law, Corporation Law, Obligations and Contracts and
Intellectual Property Law. Students are thus able to spot and address
Competition Law issues in these areas of law practice.

INTENDED COURSE OUTCOMES

Part A. Consumer Protection Law
At the end of this course, the students will be able to:
1. Identify the relevant standards for legally compliant products and services under
various trade- and industry-related laws and the liabilities of the different actors in the
supply chain for safe and quality consumer products and services;
2. Describe the standards of business conduct and sales, advertising and promotion
practices that apply to manufacturers and sellers of consumer products and providers of
consumer services; and
3. Identify and apply the proper remedy for the enforcement of specific consumer
rights and resolution of consumer issues and disputes.

Part B. Competition Law Compliance

At the end of the course, the students will be able to:
1. Identify anti-competitive agreements and conduct of persons and entities
under the Philippine Competition Act (Republic Act 10667), its IRR and other
relevant competition-related laws, and describe related concepts and
principles;
2. Identify potential Competition Law issues arising from various commercial
activities and business practices;
3. Describe the probable effects and consequences of anti-competitive
agreements and conduct; and
4. Identify possible remedies, alternatives and safeguards to eliminate or reduce
anti-competitive effects of a given agreement or conduct.
Sept 9
I. Overview

A. Constitutional Basis for Consumer Protection

1987 Constitution

1. Art. II, Sec. 15

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 2. Art. XVI, Sec. 9
3. Art. XVI, Sec. 11 (2)
4. Art. XIII, Sec. 11
5. Art. XIII, Sec. 12
6. Art. XV, Sec. 3 (2)

Case:
Roma Drug v. RTC of Guagua
G.R. No. 149907, April 16, 2009

B. Basic Concepts and Principles

1. Consumer transaction under the Consumer Act (RA 7394)

a. Art. 4, par. s), RA 7394

2. Subject matter of consumer transaction

a. Consumer products and services under the Consumer Act

Art. 4, pars. q), g), u), ab), ad), ag), ah), ak), bo), bp), RA 7394

b. Health products under the Food, Drug and Cosmetic Act (RA
3720)*, as amended by the Food and Drug Administration Act of 2009
(RA 9711)**
*Refer to amended Sec. 10 of RA 3720
**Refer to Sec. 9 of RA 9711 for amendment to Sec. 10, RA 3720

Health Products: Sec. 10, par. (ff)

Food: Sec. 10, par. (e)
Drug: Sec. 10, par. (f)
Device: Sec. 10, par. (g)
Cosmetics: Sec. 10, par. (h)
Food/dietary supplement: Sec. 10, par. (ee)
Household/urban hazardous substance: Sec. 10, par. (gg)

In-vitro diagnostic reagents: Sec. 10, par. (hh)

c. Basic necessities and prime commodities under the Price Act

(RA 7581)
Secs. 3, pars. (1), (8), RA 7581 as amended by RA 10623

d. Food under Food Safety Act of 2013 (RA 10611)

Sec. 4 (g), RA 10611

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 e. Toys and Games under the Toy and Game Safety Labeling Act of
2013 (RA 10620)
Sec. 4, RA 10620
Rule III, Secs. 1.17, 1.30, IRR of RA 10620

f. Telecommunications services under the Public

Telecommunications Policy Act (RA 7925)
Sec. 3 (a), RA 7925

g. Motor vehicles under the Lemon Law (RA 10642)

Sec. 3 (a), (j) RA 10642

h. Drugs and medicines under the Universally Accessible Cheaper and

Quality Medicines Act of 2008 (RA 9502)
Sec. 4 (c), (d) and Sec. 23, RA 9502

i. Electric service under Electric Power Industry Reform Act (RA

9136)
Sec. 41, RA 9136
Magna Carta for Residential Electricity Consumers

3. Parties involved in, liable for, and/or affected by a consumer

transaction

a. Supplier
Art. 4, par. bu), RA 7394

b. Manufacturer
Art. 4, par. ac), RA 7394
Sec. 10, Par. (v), RA 3720, as amended by RA 9711

c. Seller
(Reseller)/Distributor/Importer/Exporter/Wholesaler/Trad
er
Art. 4, pars. ac), bn), RA 7394
Sec. 10, pars. (r), (bb), (cc), RA 3720 as amended by RA 9711
Sec. 10, par. (mm), RA 3720 as amended by RA 9711

d. Buyer/Retailer/Dealer
Art. 4, par. bk), RA 7394
Sec. 10, par. (mm), RA 3720 as amended by RA 9711

e. Intellectual Property Rights Licensor and Licensee

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 Secs. 4.1, 4.2, 85, 89, 90, RA 8293 (Intellectual Property Code)
Sec. 4, pars. bf), bx) RA 7394

f. Creditor in a consumer credit transaction

Art. 4, pars. o), x) z), RA 7394

g. Agent/Contractor/Service provider (e.g., packer, transporter,

logistics service provider, warehouse operator)

h. Advertiser
Art. 4 (d), RA 7394

i. Consumer
Art. 4 (n), RA 7394

j. Third parties affected by a consumer transaction

Case:

Petron Corp. v. Sps. Jovero, et al.

G.R. No. 151038, January 18, 2012
Sept 16
4. Activities in connection with, or with a view to, consumer
transactions

a. Licensing
Art. 10 (y), (ii), RA 3720 as amended by RA 9711
Art. 31, RA 7394

b. Registration
Art. 10 (kk), RA 3720 as amended by RA 9711
Art. 31, RA 7394

c. Standardization
Art. 5, 7, 14, RA 7394
RA 4109

d. Manufacture; Labeling; Packaging

Sec. 4, pars. ar), aq), az), RA 7394
Title III, Chapter IV, RA 7394
Sec. 10, pars. (i), (jj), RA 3720 as amended by RA 9711

e. Data Collection and Processing

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 RA 10173 (Data Privacy Act)

f. Advertising
Art. 4, pars. a), b), RA 7394
Sec. 4 (a), RA 10611
Art. 110, RA 7394
Advertising Standards Council (ASC) Code of Ethics

g. Sales promotion
Art. 4, par. bm), RA 7394
Art. 109, 116-121, RA 7394

SEC-OGC Opinion No. 18-21 (28 November 2018)

Re: Mass Media; Digital Platform
DOJ Opinion No. 40, S. 1998 (March 19, 1998)
(Whether the internet constitutes mass media)

Cases:
Pepsi-Cola Products Phils. v. Pagdanganan
G. R. No. 167866, October 12, 2006

Department of Health v. Philip Morris Philippines Manufacturing, Inc.

G.R. No. 202943, March 25, 2015

Pharmaceutical and Healthcare Assoc. of the Philippines v. Duque III

G.R. NO. 173034, October 9, 2007

h. Credit transaction
Art. 4, par. y), RA 7394

i. Price monitoring and regulation

Sec. 18, 19, 23, RA 9502
Sec. 6, 7, 8, RA 7581

j. Traceability
Sec. 4 (mm), RA 10611

k. Product recall
Art. 10, RA 7394
Sec. 4 (i), RA 3720 as amended by RA 9711

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 FDA Circular 2016-012 dated 25 July 2016 (Guidelines on Product
Recall)
Sept 23
II. Rights of Consumers

Art. 2, RA 7394

1. Right to availability of basic necessities and prime

commodities at reasonable prices at all times
Sec. 5, RA 7581, as amended by RA 10623

2. Right to protection against hazards to health and safety

Title II, Chapter I, II, III, RA 7394
Secs. 14, 15, 18, 19, 23, 24, RA 3720, as amended by RA 9711
Sec. 11, RA 3720 as amended by RA 9711
Secs. 5, 6, 8, 9, 12, 13, 14, RA 10611
Sec. 4, RA 8203

3. Right against deceptive, unfair and unconscionable sales acts

and practices
Title III, Chapter I and II, RA 7394
Title III, Chapter VI, RA 7394
Secs. 3 (i), 4, RA 10909 (No Shortchanging Act of 2016)
DTI Administrative Order No. 10-04, s. 2010 (Guidelines on the Issuance,
Use and Redemption of Gift Checks, Certificates of Gift Cards)
Cases:

Autozentrum Alabang, Inc. v. Spouses Bernardo, et al.

G.R. No. 214122, June 08, 2016

Aowa Electronic Philippines, Inc. v. DTI

G.R. No. 189655, April 2011

4. Right to information and education to facilitate sound choice and

the proper exercise of rights by the consumer
Sec. 169 (False Designations of Origin; False Description or Representation),
RA 8293
Secs. 6, 7, 11, RA 6657
Sec. 29, RA 3720, as amended by RA 9711
Sec. 40, RA 10173
Secs. 13, 14, 34, 35, RA 9211

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5. Right of choice over goods and services offered in the market
under the Philippine Competition Act (RA 10667)
Sec. 2, RA 10667

6. Right to redress
Art. 11, RA 7394
Art. 68, par. f), RA 7394
Arts. 97, 100-102, 106, 122 (b), RA 7394

7. Right of representation in the formulation of social and economic

policies
Art. 156, RA 7394
Sec. 11 (9), RA 7581

8. Rights as telecommunications users under the Public

Telecommunications Policy Act
Sec. 20, RA 7925

9. Right to a healthy environment

Art. II, Sec. 16, 1987 Constitution

10. Protection of consumer rights in electronic transactions

Joint DTI – DOH – DA Administrative Order No. 1, Series of 2008 (Rules and
Regulations for consumer protection in a transaction covered by RA 7394
through electronic means under the E-Commerce Act)
BSP Circular No. 542, Series of 2006 (Consumer Protection for Electronic
Banking)
BSP Circular No. 857, Series of 2014 (BSP Regulations on Financial Consumer
Protection)
BSP Circular No. 1048, Series of 2019 (BSP Regulations on Financial
Consumer Protection)

11. Rights of privacy, security and confidentiality in matters

relating to ICT (information and communications technology)
under the Department of Information And Communications
Technology Act of 2015 (RA 10844)
Sec. 6, IV, (n), RA 10844

12. Right to privacy, security and confidentiality of personal

information under the Data Privacy Act (RA 10173)
Secs. 11-20, RA 10173

Case:

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 Vivares v St. Theresa’s College, GR No. 202666 (September 29, 2014)

13. Right against unsolicited commercial communications under the

Cybercrime Prevention Act (RA 10175)
Sec. 4 (c) (3), RA 10175

Case: Disini vs Secretary of Justice, G.R. No. 203335, February 11, 2014

14. Right to consumer protection in respect of subscriptions to

Broadcast, CATV, Telecommunications, Value Added Services
and Content Provider services
NTC Memorandum Circular No. 05-06-2007 dated 8 June 2007

15. Right to claims settlement as Planholder under the Pre-Need Code

(RA 9829)
Sec. 4, pars. b), c), d), 14, 18, 19, 25, 26, RA 9829

Case:
SEC v. Laigo, 768 SCRA 633 (2015)
G.R. No. 188639 | 2015-09-02

16. Passenger’s Rights under the Air Passengers Bill of Rights

Joint DOTC-DTI Administrative Order No. 1, Series of 2012

Sept 30
III. Legal Aspect of Consumer Transactions

A. Warranties
Art. 1545, Civil Code
Art. 1653, Civil Code
Arts. 67, 68, 70, 169, RA 7394
Sec. 3, pars. (m), (n), (h), Secs. 5-8, RA 10642

1. Express warranty
Art. 1546, Civil Code

2. Implied warranty
Arts. 1547, Civil Code

3. Warranty in case of eviction

Arts. 1548 – 1559, Civil Code

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 4. Warranty against hidden defects or encumbrances upon the
thing sold
Arts. 1561 – 1571, Civil Code
Cases:
Ang v. Court of Appeals
G.R. No. 177874, September 29, 2008

De Guzman v. Toyota Cubao, Inc.

G.R. No. 141480, November 29, 2006

Isidro v. Nissan Motor Phils.

G.R. No. 136500, December 3, 1999

G.A. Machineries, Inc. v. Yaptinchay

G.R. No. L-30965, November 29, 1983

Philippine Steel Coating Corp. v. Edward Quinones

G.R. No. 194533 (April 19, 2017)

Pilipinas Makro, Inc. v. Coco Charcoal Philippines, Inc.

GR No. 196419 (October 4, 2017)

Geromo v. La Paz Housing

G.R. No. 211175, January 18, 2017
Poole-Blunden v. Union Bank of the Philippines
G.R. No. 205838, November 29, 2017
Mendoza v. David
G.R. No. 147575, October 22, 2004
Oct 7
B. Product liability; remedies

1. Liability for damage caused by defective products and

services
Civil Code, Art. 19, 20, 21, 24
Civil Code, Art. 1161, 1162
Civil Code, Arts. 2176, 2177
Sec. 12 (a), RA 3720, as amended by RA 9711
Case:
Radio Communications of the Phils., Inc. v. Verchez

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 G.R. No. 164349, January 31, 2006

2. Strict liability; what must be proved

Civil Code, Art. 2187
Title III, Chapter V, Liability for Product and Services, RA 7394

Cases:

Coca-Cola Bottlers Philippines, Inc. v. Court of Appeals

G.R. No. 110295, October 18, 1993

Navida, et al. v. Hon. Teodoro Dizon, Jr.

G.R. No. 125078, May 30, 2011

Moran, Jr. v. Office of the President

G.R. No. 192957, September 29, 2014

Nutrimix Feeds Corp. v. Court of Appeals

G.R. No. 152219, October 25, 2004

3. Defects liability period

Civil Code, Art. 1719, Art. 1723, Art. 1727

Case:
William Golanco Construction Corporation vs PCIB
G.R. No. 142830, March 24, 2006

4. Corporate criminal liability; liability of corporate officers

Case:
Ching vs. Secretary of Justice
G.R. 164317, 6 February 2006

C. Contract of Adhesion

Cases:

Radio Communications of the Phils., Inc. v. Verchez

G.R. No. 164349, January 31, 2006

Cabanting v. BPI Family Savings Bank, Inc.

G.R. No. 201927, February 17, 2016

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Oct 14
D. Consumer Issues

1. Unauthorized entities and activities

2. Unregistered products

Case:

Republic v. Drugmaker’s Laboratories, Inc.

G.R. No. 190837, March 5, 2014

3. Adulteration
Case:
Department of Health v. Phil Pharma Wealth, Inc.
G.R. No. 182358, February 20, 2013
4. Misbranding or mislabeling
5. Underfilling
6. Counterfeit Products
7. Unfair Competition (Passing Off)
8. False and/or Misleading Advertising and Promotion
9. Unauthorized access and/or misuse of personal and
confidential information
10. Fraud
11. Negligence in supply of products or provision of services

Case:

Mercury Drug Corp. v. De Leon

G.R. No. 165622, October 17, 2008

Radio Communications of the Phils., Inc. v. Verchez

G.R. No. 164349, January 31, 2006

Oct 21
Closing Activity:
Drafting pleadings based on a hypothetical product recall scenario:
Group 1 – Memorandum for Complainant
Group 2 – Memorandum for Defendant
Group 3 - Decision

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Oct 28 - midterms

Nov 4 [For Nov 23 overview]

IV. Regulation of Business Conduct and Trade Practices

A. Self-regulation in Advertising
ASC Code of Ethics (part of ASC Guidebook), available at
http://asc.com.ph/wp-content/uploads/2016/06/ASC_Guidebook.pdf

B. Regulating Competition in the Market

1. Overview of competition

2. The Necessity for Competition Law

1987 Constitution, Article XII, Sec. 1, Sec. 6, Sec. 19
Republic Act No. 10667, Philippine Competition Act (PCA), Sec. 2
Case:
Tatad v. Secretary of the Department of Energy
281 SCRA 330 (1997)

3. Basic Concepts and Principles

a. Entity

PCA, Sec. 4 (h)

Case:
Intel Corporation v. Commission, Judgment of the Court, Case C-
413/14P, EU:C:2017:632 (September 6, 2017)

b. Agreement

PCA, Section 4(b)

PCA, Section 3

c. Horizontal agreement and Vertical agreement

d. Monopolies

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 Case:

Agan, Jr. v. Philippine International Air Terminals Co., Inc.

402 SCRA 612 (2003)

e. Cartels; express cartels; hub and spoke cartels

RA 7581, Price Act, Section 5

PCA, Sec. 14

f. Combinations in restraint of trade

Case:

Gokongwei, Jr. v. Securities and Exchange Commission

89 SCRA 336 (1979)

g. Dominant Position; Abuse of Dominant Position

PCA, Sec. 4 (g)

PCA, Sec. 15

Rule 8 (Determination of Dominance), IRR, PCA

Nov 11 [For Dec 2, first hour]
Case:

Hoffman-La Roche v. Commission, Judgment of the Court,

Case 85/76, ECLI:EU:C:1979:36 (13 February 1979), available at
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:61976CJ0085&from=EN

Read pp. 508-509, 514-524, 535-547

h. Tying arrangements and Exclusive Dealing Arrangements

PCA, Sec. 15 (c)

Case:

United States vs. Microsoft Corp.

253 F.3d 34 (D.C. Cir. 2001)

i. Block-booking and Pooling Agreements

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 Case:
United States vs Paramount Pictures, Inc., 334 US 131 (1948)

j. Exclusivity and undue restraint of trade

Case:

Avon Cosmetics, Inc. v. Luna

511 SCRA 376 (2006)

k. Fair competition vs ruinous competition

Cases:

Energy Regulatory Board v. Court of Appeals

G.R. No. 113079, April 20, 2001

l. Unfair Competition

Civil Code, Art. 28

Cases:

Willaware Products Corporation v. Jesichris Manufacturing

Corporation
734 SCRA 238 (2014)

Coca-Cola Bottlers, Phils., Inc. v. Gomez

571 SCRA 18 (2008)

m. Relevant Market; Hypothetical Monopolist/SSNIP Test;

Cross-Price Elasticity

PCA, Sec. 4 (k)

PCA, Sec. 24
PCC Merger Review Guidelines, Part 5 (Market Definition),
pars. 5.10- 5.16

Cases:

Avon Cosmetics v. Luna, 511 SCRA 376 (2006)

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 PCC Commission Decision No. 03-M-021/2019, Proposed Acquisition
by Universal Robina Corp. of Assets of CADPI ad RHI

Nov 18 [for Dec. 2, second hour]

n. Price fixing; scrutiny of price fixing

PCA, Sec. 14 (a) (1), (2)

o. Single Economic Entity

PCA, Sec. 14, last paragraph

p. Resale Price Maintenance; Most Favored Nation (MFN)

Clause

PCA, Sec. 14 (c)

PCA, Sec. 15 (e)

Case:
Leegin Creative Leather Products, Inc. v. PSKS, Inc.
551 US 877 (2007)

Commission Decision, Case AT.40153 – E-book MFNs and related

matters (2017), available at
https://ec.europa.eu/competition/antitrust/cases/dec_docs/40153/40
153_4392_3.pdf

o. Predatory Pricing

PCA, Sec. 15 (a)

Case:

Energy Regulatory Board v. Court of Appeals

357 SCRA 30 (2001)

Brooke Group Ltd. v. Brown and Williamson Tobacco Corp.

509 U.S. 209 (1993)

Nov 25 [For Dec 9, first hour]

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4. Monopolies and the Government

a. 1987 Constitution, Art. XII, Sec. 11

Case:

Tawang Multi-Purpose Cooperative vs La Trinidad Water District

646 SCRA 20 (2011)

b. 1987 Constitution, Art. XII, Sec. 19

Cases:

Garcia vs Executive Secretary

583 SCRA 118 (2009)

c. Interface between Competition Law and Intellectual

Property Rights; essential facilities

RA 8293 (as amended by RA 9502), Sec. 74, Sec. 93, Sec. 93-A, Sec. 97
RA 8293 (as amended by RA 9502), Sec. 87, Section 88
PCC Clarificatory Note No. 19-001 (Coverage of Compulsory Notification
in Land Acquisition)

Case:

E. I. Du Pont de Nemours and Co. vs. Dir. Emma C. Francisco, et al.

G.R. No. 174379 (2016)

Distilleria Washington v. La Tondena Distillers, et al. G.R. No. 120961.

October 2, 1997

5. Main prohibitions under the PCA

a. Anti-competitive agreements prohibited per se; Hardcore cartels;

agreements with object or effect of substantially lessening competition;

PCA, Sec. 14 (a), Sec. 26, Sec. 30

b. Abuse of dominant position

PCA, Sec. 15, Sec. 27

IRR, Rule 8, sec. 5
IRR, Rule 3, sec. 3

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 c.Anti-competitive mergers and acquisitions
PCA, Sec. 20
IRR, Rule 4

Dec 2 [Dec. 9, second hour]

6. “Windows of Opportunity” within the PCA

a. Exemptions from Prohibited Mergers and Acquisitions

PCA, Sec. 21, Sec. 22

b. Exceptions to Anti-Competitive Agreements; Rule of Reason Analysis

PCA, Sec. 14 (c), Sec. 26

c. Exceptions to Abuse of Dominant Position

PCA, Sec. 15
IRR, Rule 8, sec. 5; Rule 3, sec. 3

d. Forbearance

PCA, Sec. 28

e. Trade Associations

PCA, Sec. 48

7. Enforcement and Remedies

a. Powers, Functions and Jurisdiction of the Philippine Competition

Commission

PCA, Chapter II, Section 12

PCA, Sec. 31, last paragraph
PCA, Sec. 32

b. Investigations, Non-adversarial Remedies, Adjudication

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 Rules of Procedure of the Philippine Competition Commission
Dec 9 [Dec. 16, first hour]
c. PCC Review of Mergers and Acquisitions

PCA, Chapter IV
PCC Rules on Merger Procedure
PCC Merger Review Guidelines
PCC Memorandum Circular No. 18-001; Commission Resolution No.
01-2020
PCC Clarificatory Notes on Notification
PCC Guidelines on Notification of Joint Ventures: The treatment of
joint ventures

PCC Commission Decisions on Mergers and Acquisitions at

phcc.gov.ph

d. Enforcement and Leniency

PCA, Chapter VII

Rules of the Leniency Program of the PCC

e. Prohibition on Issuance of Injunction

Chapter VIII, Section 47

f. Dawn Raid Investigations

PCA, Section 12 (g)

A.M. 19-08-06 (Rule on Administrative Search and Inspection under
the Philippine Competition Act)

g. Fines and Penalties

PCA, Chapter VI
PCA, Section 41
Act No. 3247, Section 6

h. Private Action; claim for damages under the Civil Code

PCA, Sec. 45
Civil Code, Art. 28

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Dec 16 [Dec. 16, second hour]

Final Report: Competitive Analysis of Trade Practices

• Group boycott
• Loyalty Rebates
• Growth Bonuses
• Exclusivity (e.g., ice cream freezer exclusivity)
• Tying and Bundling
• Open Book Pricing
• Sharing of Commercially Sensitive Information
• Use of Competitor Intelligence, Benchmarking
• Joint Purchasing
• Joint Research and Innovations
• Joint Production Agreements
• Joint Marketing (e.g., co-branding)
• Joint Sustainability Initiatives
• Welcome Packs, Wargames and Wargames Language
• Standardization of products (within an industry)
• Category Management and Shelf Space Arrangements
• Loan syndication

Jan 6, 2021 – Continuation of reports and wrap-up

Jan 13, 2021 – Finals

- Nothing Follows –

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