Why RA 10350 Splits Enforcement in Two, And Why Your Complaint Might Land in the Wrong Office

If you've ever tried to file a complaint against someone practicing interior design without a license, you may run into a confusing wall: neither the Professional Regulatory Board (PRB) for Interior Design nor the Professional Regulation Commission (PRC) may be able to take administrative action, because the person was never registered in the first place.

It can feel like a loophole. It isn't. It's actually how the Philippine Interior Design Act of 2012 (Republic Act No. 10350) was deliberately designed, and understanding why makes the whole system click into place.

Two Different Problems, Two Different Tools

RA 10350 doesn't have one enforcement mechanism. It has two, and they're built to catch two very different kinds of violators.

1. The Administrative Track (Sections 21 and 36)

This track exists for people already inside the profession: licensed, registered interior designers (IDrs) who violate the Code of Ethics, act incompetently, or otherwise fall short of professional standards. The Board and the Commission handle this because they have real leverage over these individuals, namely a license that can be suspended or revoked.

Section 36 spells this out plainly. The Commission is tasked to implement the law, enforce its Implementing Rules and Regulations, investigate complaints, and prosecute violations of the Code of Conduct. But this machinery only works on someone who has something the regulator can take away.

2. The Criminal Track (Section 34)

This track exists for the opposite case: people who were never part of the licensing system in the first place, such as unregistered individuals practicing interior design without authorization, or people impersonating a licensed IDr.

Since these individuals hold no license, there's nothing for the Board or Commission to revoke. So the law reaches for a different tool entirely: criminal penalties. Section 34's Penal Clause imposes a fine of ₱300,000 to ₱1,000,000, imprisonment of six months to three years, or both, at the court's discretion, covering acts like practicing without registration, abetting unauthorized practice, or impersonating a registered IDr. Foreign practitioners or firms caught practicing illegally face even steeper consequences: a fine equal to 30% of gross fees plus back taxes, the same imprisonment range, and a permanent ban from practicing in the Philippines.

Why the Law Is Built This Way

This isn't a drafting oversight. It reflects a structural limit baked into Philippine administrative law.

PRC is an administrative agency. Its authority comes from the regulatory relationship it has with the professionals it licenses. It can discipline, suspend, and revoke, but only within that relationship. It has no constitutional power to imprison anyone or impose criminal fines; only the courts can do that, through a case built by a prosecutor.

So when someone practices without ever entering PRC's licensing system, PRC's administrative machinery is, by design, powerless to touch them. Section 34 exists precisely to fill that gap, giving the public a criminal remedy for a problem the administrative track was never built to solve.

What This Means If You're the One Filing a Complaint

Situation	Applicable Track	Where to File
Respondent is a licensed, registered IDr who violated ethics or standards	Administrative (Sec. 21, 36)	PRC Legal and Investigation Division or the PRB Secretariat
Respondent is unlicensed and practicing anyway, or impersonating an IDr	Criminal (Sec. 34)	Office of the City/Provincial Prosecutor, with PRC/NBI assistance in building the case

If your case is the second scenario, the lack of an administrative remedy makes technical sense, but it isn't the end of the road. You (or a licensed IDr, or the accredited professional organization) can still:

1. Report the matter to PRC's Legal and Investigation Division. They won't discipline the person, since there's no license to act on, but they can investigate and refer or assist with prosecution.

2. File a criminal complaint-affidavit for violation of Section 34 with the Prosecutor's Office that has jurisdiction where the offense occurred.

   
   

It's a slower, more formal path than an administrative complaint, but it's the one the law actually built for this exact situation.

This Isn't Unique to Interior Design (RA 10350)

If this feels like an unusually complicated setup, it's worth knowing it isn't specific to RA 10350. The same administrative-versus-criminal split shows up across nearly every Philippine professional regulatory law: the Architecture Act, the various Engineering laws, the Real Estate Service Act, and others all separate discipline of licensed professionals (handled by PRC/the relevant Board) from penalties for unlicensed practice (handled by the courts, via a criminal complaint).

The takeaway: when a regulator can't act administratively on a complaint, it's often not a dead end. It's a signal that you're knocking on the wrong door for the type of violation involved, and there's usually a different, still-valid door right next to it.

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Disclaimer: This article is for general informational purposes and reflects a plain-language reading of RA 10350 and related PRC procedures. It is not legal advice. If you're pursuing an actual complaint, consult a lawyer or the relevant PRC office to confirm current procedures and requirements.