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[20] An Act Amending Republic Act No. 8042, otherwise known as the Migrant Workers
and Overseas Filipinos Act of 1995, as amended, Further Improving the Standard of
Protection and Promotion of the Welfare of Migrant Workers, Their Families and
Overseas Filipinos in Distress, and for Other Purposes.
The same rule was,reiterated in Section 5, Rule VII of the Omnibus Rules and
Regulations Implementing the Migrant Workers and Overseas Filipinos Act of 1995, as
amended by R.A. 10022.
[21] 740 Phil. 403, 459 (2014).
[22] Id.
[23] Id. at 448.
[24] See Serrano v. Gallant Maritime Services, Inc., 601 Phil. 245, 306 (2009).
[25] Rollo, p. 19.
[26] Id. at 368.
[27] Id. at 176.
[28] Id. at 243.
[29] Id. at 67.
[30] 676 Phil. 262 (2011).
[31] Id. at 270.
[32] The general rule,under Article 2208 of the Civil Code is that "[i]n the absence of
stipulation, attorney's fees and expenses of litigation, other than judicial costs, cannot
be recovered x x x." (Emphasis ours)
[33] Supra note 30 at 275.
[34] See id. at 276.
[35] Rollo, p. 65.
[36] G.R. No. 225433, August 28, 2019.
[37] 716 Phil. 267 (2013), citing Eastern Shipping Lines, Inc. v. Court of Appeals, 304
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