PANGOLIN TRADE IN THE PHILIPPINES

I. BACKGROUND

The pangolin trade is the illegal poaching, trafficking, and sale

of pangolins, parts of pangolins, or pangolin-derived products.
Pangolins, also known as scaly ant eaters, are currently among the
world's most trafficked mammals, accounting for as much as 20% of
all illegal wildlife trade.1 They are especially sought after in Asia and
Africa for their meat and scales, with the latter used for traditional
medicinal purposes, while their meat is consumed as a luxury dish or
local source of protein.2 There are only eight species of pangolins
which can be found in Africa, China, Malaysia, India and the
Philippines. According to the International Union for Conservation of
Nature (IUCN), a non-profit organization working to protect wild
animals and their environment, more than a million pangolins were
poached in the decade prior to 2014.3 Of the four Asian pangolin
species, IUCN has listed the Sunda or Malayan pangolin (Manis
javanica), and the Chinese pangolin (Manis pentadactyla) as critically
endangered while the Indian (Manis crassicaudata) and the Philippine
pangolin (Manis culionensis) endemic to Palawan have been classified
as endangered in its Red List of Threatened Species.4

The Convention on International Trade in Endangered Species

(CITES), which regulates the international wildlife trade, has placed
restrictions on the pangolin market since 1975, and in 2016, it added
all eight pangolin species to its Appendix I, reserved for the strictest
prohibitions on animals threatened with extinction.5 Despite restrictions
on trade in place since 1975, enforcement is not uniformly strong. Most
efforts have focused on curbing the supply side of the trade, but
demand remains high and there is a thriving black market.6 In 2014,
the Worldwatch Institute reported that more pangolins were seized
than any other animal in Asia's wildlife black market and that it is now

1 Guy Kelly, Pangolins: 13 facts about the world’s most hunted animal, The Telegraph (1 January
2015).
2 Shairp et al., Understanding urban demand for wild meat in Vietname: implications for

conservation actions (2016).

3 Eating pangolins to extinction, International Union for Conservation of Nature,

https://www.iucn.org/content/eating-pangolins-extinction (last updated 29 July 2014).

4 Rhishja Cota, All 8 Pangolin Species Threatened with Extinction; 2 Species Now ‘Critically

Endangered’, https://www.pangolins.org/2014/08/15/all-8-pangolin-species-threatened-with-
extinction-2-species-now-critically-endangered (last updated 15 August 2014).
5 Damian Carrington, Pangolins thrown a lifeline at global wildlife summit with total trade ban, The

Guardian (28 September 2016).

6 Guy Kelly, Pangolins: 13 facts about the world’s most hunted animal, The Telegraph (1 January

2015).
the most frequently seized mammal in Asia’s black-market wildlife
trade.7 The largest seizure of pangolin was recorded last 2013 when a
Chinese boat ran into the Tubbataha Reefs National Park in Palawan
carrying ten (10) tonnes of frozen pangolins.8

This paper discusses all known pangolin trade in the Philippines

through an analysis of seizures that have occurred between 2001 and
2017 despite the pertinent laws against it.

Concentration of Pangolin in the Philippines

The Philippines is home to one species of pangolin, the Philippine

or Palawan Pangolin Manis culionensis, so named due to its restricted
range on Palawan and adjacent islands.9 It is endemic particularly in
Busuanga Island, including the municipalities of Calauit and Coron,
Coron Island, Culion Island, and Dumaran Island. It has also been
introduced to Apulit Island.10 It is considered to be more abundant in
the northern and central parts of Palawan Island and much rarer in the
south.11 This species is found in primary and secondary lowland
forests, lowland grassland and forest mosaic, including near human
habitation, providing there is suitable vegetative cover such as
abundant trees and logs.12

As with other pangolins, this species feeds on termites and ants. It

has the greatest number of scale rows across its back of all Asian
pangolins and can be distinguished from the Malayan pangolin by its
smaller scales and a shorter head and body to tail length ratio.13 The
Philippine Pangolin was listed as Endangered on the IUCN Red List of
Threatened Species in 2014 as wild populations have declined by
more than 50% over a period of 21 years.14 Aside from its restricted
range and habitat loss, subsistence hunting and exploitation for

7 Gwynn Guilford, Demand for traditional Chinese medicine is killing off the world’s quirkiest
animal, Quartz (27 January 2014).
8 Damian Carrington, Chinese vessel on Philippine coral reef caught with illegal pangolin meat,

The Guardian (15 April 2013).

9 (Gaubert and Antunes, 2005; Lagrada et al., 2014).
10 Lagrada, L., Schoppe, S. & Challender, D. 2014. Manis culionensis. The IUCN Red List of

Threatened Species (2014).

11 Sabine Schoppe and Rommel Cruz, The Palawan Pangolin Manis culionensis, TRAFFIC

Southeast Asia (2009).

12 Id.
13 Philippine Pangolin, IUCN SSC Pangolin Specialist Group (December 14, 1:30 AM),

https://www.pangolinsg.org/pangolins/philippine-pangolin.
14 Lagrada, L., Schoppe, S. & Challender, D. 2014. Manis culionensis. The IUCN Red List of

Threatened Species (2014).

national and international trade are the biggest threats causing
population declines.15

II. THE BLACK MARKET OF PANGOLIN TRADE

The value of Illegal Wildlife Trade in the Philippines is estimated

to be Php 50 billion a year roughly equivalent to US $1 billion, which
includes the market value of the wildlife and resources, their ecological
role and value, and damage to habitats incurred during poaching, and
loss in potential ecotourism revenues.16
The black market pangolin trade is primarily active in Asia.
Demand is particularly high for their scales, but whole animals are also
sold either living or dead for the production of other products with
purported medicinal properties or for consumption as exotic food. At
least 67 countries and territories across six continents were implicated
in the trafficking of pangolins between 2010 and 2015 indicating the
global scale of illegal trade and the associated threat to pangolins.17

Capture and trade of Philippine Pangolin is still flourishing

despite the ban

The Manis culionensis is hunted at a local, subsistence level for

consumption of its meat, but also for trade at a national and
international level for its blood, meat, skins, and scales. 18 It is traded
for food and traditional medicine on Palawan and from Palawan to
Manila. The scales are in trade for Traditional Chinese Medicine, as
part of the shift to market economies among the Tagbanua and other
ethnic groups on Palawan.19 While this species has been reported in
international trade historically, since the last assessment in 2008, there
is evidence of a tangible illicit international trade involving this species,
both directly to China for use in traditional medicines, and to Sabah
(Kudat, Sandakan), East Malaysia and Peninsular Malaysia. 20

The total trafficked volume of pangolins in the Philippines was

estimated to be 3,537. In most cases, the Philippines was implicated
as a source country as well as an end-use destination. Based on the
seizure incidents that occurred outside Palawan province, there

15 Lalita Gomez and Emerson Sy, Illegal Pangolin Trade in the Philippines, 30, TRAFFIC Bulletin,
37, 37 (2018).
16 The World Bank Group, Addressing the Illegal Wildlife Trade in the Philippines (Dec. 16, 2018,

9:30 AM) http://pubdocs.worldbank.org/en/997621542735912298/Illegal-Wildlife-trade-brochure-

ADBDENR18NovforWEB.pdf.
17 Heinrich et al., The Global Trafficking of Pangolins: A comprehensive summary of seizures and

trafficking routes from 2010-2015, TRAFFIC (2017).

18 Sabine Schoppe, and Rommel Cruz, The Palawan Pangolin Manus culionensis, TRAFFIC

South East Asia (2009).

19 Lagrada, L., Schoppe, S. & Challender, D. Manis culionensis. The IUCN Red List of

Threatened Species (2014).

20 Sabine Schoppe, and Rommel Cruz, The Palawan Pangolin Manus culionensis, TRAFFIC

South East Asia (2009).

appears to be a local demand for pangolin meat as a luxury food item
and scales for traditional medicine, particularly in Metro Manila. 21

There were at least ten seizures that implicated Manila as a

major market for pangolins, including a mixture of live and frozen
animals, presumably for the exotic food industry. More recently,
between January and March 2018, there have been further seven
incidents of pangolins found roaming the streets of Metro Manila and
an additional seizure of two live pangolins that were offered for sale,
but no arrests have been made to date in any of these cases.22 Foreign
nationals from mainland China and Taiwan residing in the country have
also been implicated in several seizures.23

Live or frozen pangolins and cooked pangolins, based on recent

market observations sell for PHP12,000 (USD233) per kilogram and
PHP14,000 (USD272) per kilogram, respectively, in Metro Manila.24

The seizure data demonstrate that the Philippine Pangolin is actively

being sought for local, national, and likely international trafficking, to
meet demand for its meat and scales, despite being a Critically
Endangered endemic species and one that is protected in the
Philippines.

III. LAWS AND STATUTES PROHIBITING THE TRADE

International Law
1. Convention on International Trade in Endangered Species of Wild
Fauna and Flora (CITES)

The Convention on International Trade in Endangered Species of

Wild Flora and Fauna (CITES)25 is a multilateral treaty that protects
endangered plants and animals and seeks to ensure that international
trade in wild animals and plants does not threaten their survival.
Pursuant to Article II, paragraph 1, of CITES, “Appendix I shall include
all species threatened with extinction, which are or may be affected by
trade.”26 Thus, during the 17th Conference of the Parties of the CITES
in 2016, all eight species in the pangolin family were listed in the
Appendix I from being under Appendix II providing for a modest level

21 Lalita Gomez and Emerson Sy, Illegal Pangolin Trade in the Philippines, 30, TRAFFIC Bulletin,
37, 38 (2018).
22 Id.
23 Id., at 39.
24 Id.
25 Convention on International Trade in Endangered Species of Wild Flora and Fauna, Mar. 3,

1973.
26 Convention on International Trade in Endangered Species of Wild Flora and Fauna, Art. 2, Mar.

3, 1973.
of protection since 1994. The 182 member nations of CITES which the
Philippines is a signatory of unanimously agreed a total ban on
international trade on all pangolin species.27

Philippine Laws
1. Wildlife Resources Conservation and Protection Act (R.A. No. 9147)
The Republic Act No. 9147, or the Wildlife Resources Conservation
and Protection Act, prescribes various penalties for illegal acts toward
threatened species under Section 27 and 28:
SECTION 27. Illegal Acts. — Unless otherwise allowed in
accordance with this Act, it shall be unlawful for any person to
willfully and knowingly exploit wildlife resources and their
habitats, or undertake the following acts:

(a) killing and destroying wildlife species, except in the following

instances;
(i) when it is done as part of the religious rituals of
established tribal groups or indigenous cultural
communities;
(ii) when the wildlife is afflicted with an incurable
communicable disease;
(iii) when it is deemed necessary to put an end to the
misery suffered by the wildlife;
(iv) when it is done to prevent an imminent danger to the
life or limb of a human being; and
(v) when the wildlife is killed or destroyed after it has been
used in authorized research or experiments.
(e) trading of wildlife;
(f) collecting, hunting or possessing wildlife, their by-products
and
derivatives;
(i) transporting of wildlife.

SECTION 28. Penalties for Violations of this Act. — For any

person who undertakes illegal acts under paragraph (a) of the
immediately preceding section to any species as may be
categorized pursuant to this Act, the following penalties and/or
fines shall be imposed:
(a) imprisonment of a minimum of six (6) years and one (1) day
to twelve (12) years and/or a fine of One hundred thousand

27Damian Carrington, Pangolins thrown a lifeline at global wildlife summit with total trade ban,
The Guardian (28 September 2016).
 pesos (100,000.00) to One million pesos (1,000,000.00), if
inflicted or undertaken against species listed as critical;28
Under the law, the illegal transport of pangolin may merit
imprisonment of up to one year and a fine of up to P100,000. A jail term
of up to four years and a fine of P300,000 await those who will be found
guilty of trading pangolin. The killing of pangolin carries a jail term of
up to twelve years and a fine of up to P1 million.29
2. Palawan Council for Sustainable Development (PCSD) Resolution
No 15-521
Since 2015, the Palawan Council for Sustainable Development
(PCSD) has listed M. culionensis as Critically Endangered through the
issuance of PCSD Resolution No. 15-52130 in compliance with RA
9147.
In an effort to curb illegal wildlife trade, which includes Philippine
pangolin, the Palawan Council for Sustainable Development Staff
(PCSDS) since 2010 has established its Enforcement Team and
Wildlife Traffic Monitoring Units (WTMUs) pursuant to its mandate to
enforce the R.A. 9147 or the Wildlife Resources Conservation and
Protection Act in the province.31

IV. COMPLIANCE AND ENFORCEMENT OF LAWS

It is the member nations of the Convention on International Trade

in Endangered Species of Wild Flora and Fauna that must enforce its
regulations in their own countries, although the CITES Standing
Committee have a mechanism to recommend trade suspensions on
countries that are persistent offenders. However, CITES cannot simply
force member countries to take necessary action to combat a highly
organized criminal system worth tens of billions of dollars. A recent
investigation by an international law firm, DLA Piper found that most
countries in which wildlife trafficking takes place have serious
weaknesses in governance, resulting in very few prosecutions.32
There is an obscene amount of pangolin seizures in the
Philippines but very few people are arrested and even fewer are
convicted under R.A. No. 9147 or the Wildlife Resources Conservation
28 Wildlife Resources Conservation and Protection Act, R.A. 9147 § 28 ( July 30, 2001)
29 Department of Environment and Natural Resources, DENR Warns Against Illicit Pangolin
Trade, http://www.denr.gov.ph/news-and-features/latest-news/2787-denr-warns-against-illicit-
pangolin-trade.html (last updated Oct. 9, 2016).
30 Approving the 2014 Updated List of Terrestrial and Marine Wildlife in Palawan and their

Categories Pursuant to R.A. No. 9147, PCSD Resolution No. 15-521 (Feb. 26, 2015)
31 Palawan Council for Sustainable Development, World Pangolin Day 2016: Efforts to protect

Palawan pangolin continue, https://pcsd.gov.ph/igov/2016/02/20/world-pangolin-day-2016-efforts-

to-protect-palawan-pangolin-continue (last updated Feb. 20, 2016).
32 Anna Heath, Spotlight on CITES, Synchronicity Earth (Oct. 26, 2016).
and Protection Act. While the Palawan Council for Sustainable
Development and the Department of Environment and Natural
Resources have been enforcing applicable laws, many regional wildlife
offices are still considered reactive, if not inactive.

V. CONCLUSION

In so far as the a total ban on international trade on all pangolin

species, it is apparent that CITES has been ineffective in controlling
the illegal trade internationally. Many of its member countries lack the
strong governance needed to effectively enforce CITES restrictions.
Despite the pertinent laws against the trade of the Philippine pangolin,
the enforcement of which had not kept pace with the demand for the
pangolin meat and scales.
Considering its threatened status, the Philippine Pangolin may
be facing as perilous a fate as its other Asian counterparts if immediate
action is not taken to clamp down on poaching and trafficking of this
species. The national and regional wildlife authorities should enhance
its enforcement efforts and take immediate and appropriate action
against anyone found hunting, selling or in possession of pangolins
and to prosecute them to the full extent of the law. Greater resources
should also be allocated to investigate and identify primary traders,
poachers and corrupt practices at seaports and airports involved in
pangolin trafficking, and appropriate charges filed in court.
Conservation organizations should continue to monitor the trade in
pangolins and assess the scale of the threat, including its impact on
local and national populations, and inform authorities of emerging
trends in order to secure the long-term survival of this species.