Policy recommendations are then formulated to address the identified gaps or weaknesses in the protection of the rights of OFWs. 2.4 Methodology A combination of quantitative and qualitative research methods was utilized in this study. Secondary data obtained from various government agencies, non-governmental organizations and other online sources of information were used. In analyzing the cases involving OFWs decided by the Supreme Court for the five (5) year period 2015-2019, copies of the decisions of the Supreme Court were accessed from the Supreme Court website7 and other online law libraries.8 The cases were then tabulated per year and categorized according to: (a) number of OFWs involved per case; (b) sex of OFWs parties to the cases; (c) landbased or sea based OFWs; and (d) nature of principal legal issues involved. Key migrant rights issues that were the subject of the cases or discussed as part of the narrative of facts of the cases were identified and analyzed. Cases decided by the Supreme Court involving OFWs claims arising from their overseas employment contract were given special attention. The length of time it took for the cases to be resolved from the date of filing until the date of decision by the Supreme Court were tabulated and analyzed. Policy recommendations were then formulated to address the identified policy gaps or weak areas in the human/migrant rights protection mechanisms for OFWs. The findings and policy recommendations of other studies on the same subject were also taken into consideration. Key migrant rights issues that were the subject of the case or discussed as part of the narrative of facts of the cases were also reviewed and analysed, taking into consideration the findings and policy recommendations of other existing studies or research on the same subject. 2.5 Limitations of the Study Not all cases on labor migration reach the Supreme Court. Only those cases that fall within the jurisdiction of the Supreme Court are heard by the Court. The bulk of overseas labor migration cases that reach the Supreme Court tends to be grouped into the following: (a) illegal recruitment and estafa - either because the criminal penalty imposed requires judicial review of the Supreme Court, or the accused opted to exhaust the entire appeals process; (b) illegal dismissal cases and other money claims arising from, or relating to, overseas employment, including claims for damages; (c) claims for disability and death benefits by the seafarers; and (d) cases involving pure questions of law. 7 8 http://sc.judiciary.gov.ph/ lawphil.net and chanrobles.com 6