5/19/2021 E-Library - Information At Your Fingertips: Printer Friendly [37]Id. at 513-514. [38]Definition taken from (visited September 10, 2019). [39]Definition taken from (visited September 10, 2019). [40]LABOR CODE OF THE PHILIPPINES, Article 192(2) [renumbered Article 198(b)]; Implementing Rules and Regulations of the Labor Code of the Philippines, Rule X, Section 2; Elburg Shipmanagement Phils., Inc. v. Quiogue, Jr., 765 Phil 363 (2015). [41]Jebsens Maritime, Inc., v. Mirasol, G.R. No. 213874, June 19, 2019. [42]Id. [43]Rollo, p. 573. [44]Elburg Shipmanagement Phils., Inc. v. Quiogue, Jr., 765 Phil 341, 358-359 (2015). [45]Id. at 363. [46]Id. [47]Orient Hope Agencies, Inc., v. Jara, G.R. No. 204307, June 6 2018. [48]Id. [49]Id. [50]Art. 2208. In the absence of stipulation. Attorney's fees and expenses of litigation other than judicial costs, cannot be recovered except: xxxx (2) When the defendant's act or omission has compelled the plaintiff to litigate with third persons or to incur expenses to protect his interest; Source: Supreme Court E-Library This page was dynamically generated by the E-Library Content Management System (E-LibCMS) https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66559 10/10