SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

 July 12, 2012

Via E -mail
Ms. Ma . Lourdes C. Rausa -Chan
Senior Vice President, Corporate Affairs and
Legal Services Head and Corporate Secretary
Philippine Long Distance Telephone Company
Ramon Cojuangco Building
Makati Avenue
Makati City, Philippines

Re: Philippine Long Distance Telephone Company
Form 20-F
Filed March  28, 201 2
File No. 001-03006

Dear  Ms. Rausa -Chan :

 We have limited our review to only your financial statements and related
disclosures and do not intend to expand our review to other portions of your documents.
Please comply with the following comments in future filings.  Confirm in writing that
you will do so and explain to us how you intend to comply.   In some of our comments,
we may ask you to provide us with  information so we may better understand your
disclosure.

Please respond to this letter within ten business days  by providing the requested
information  or by advising us when you will provide the requested response.   If you do
not believe our comments apply to your facts and circumstances, please tell us why in
your response.

After reviewing the information you provide in response to these  comments, we
may have  additional comments.

Form 20 -F for the fiscal year ended December  31, 2011

Notes to Consolidated Financial Statements

Note 2 6.  Provisions and Contingencies, page 288

Ms. Ma. Lourdes Rausa -Chan
Philippine Long Distance Telephone Company
July 12, 201 2
Page 2

 1. We refer to your disclosure in the last sentence of the note on page 294 indicating
that certain disclosures required by IAS 37 were not provided as it may prejudice
your position in ongoing claims, litigations and assessments.  IAS 37, paragraph
92, indicates that the omission of the required disclosures may occur in extremely
rare cases.  In that regard, tell us the reason why you are unable to provide all of
the required disclosures in aggregate by class.  Also tell us the aggregate amount
of provisions you have accrued as of December 31, 2011 and 2010 related to
contingencies.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securi ties
Exchange Act of 1934 and all applicable Exchange Act rules require.   Since the company
and its management are in possession of all facts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy of the disclosures they hav e made.

In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure in respons e to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws  of the
United States.

You may contact Leigh Ann Schultz at (202) 551 -3628 or Terry French ,
Accounting Branch Chief , at (202) 551 -3828 if you have questions regarding these
comments.  You may also contact me at (202) 551 -3815 with any other questions.

Sincerely,

/s/ Terry French for

Larry Spirgel
Assistant Director