[15] Id.   [16] Supra note 1.   [17] Id.   [18] See e.g., China Banking Corporation v. Mondragon International Philippines, Inc. and Antonio Gonzales, G.R. No. 164798, 17 November 2005; Vicar International Construction, Inc. v. FEB Leasing and Finance Corporation (now BPI Leasing Corporation), G.R. No. 157195, 22 April 2005, 456 SCRA 588; Wack Wack Golf and Country Club v. NLRC, G.R. No. 149793, 15 April 2005, 456 SCRA 280; General Milling Corp. v. NLRC, 442 Phil. 425 (2002).   [19] Shipside Incorporated v. Court of Appeals, 404 Phil. 981 (2001).   [20] 332 Phil. 733 (1996).   [21] 391 Phil. 303 (2000). [22] The Court notes that while petitioners may have initially failed to submit a secretary's certificate showing that Adorable was authorized by the Havtor Management (Philippines), Inc.'s board of directors to file the petition, they substantially complied with this requirement when they filed their motion for reconsideration. Havtor Management Philippines, Inc. v. NLRC, 423 Phil. 509, 513 (2001). [23] Bernardo v. NLRC, 325 Phil. 371 (1996).   [24] See POEA Rules, Part II, Sec. 1(f).   [25] 3 CASTAN, 7th Ed., p. 73. Cited in JURADO, COMMENTS AND JURISPRUDENCE IN OBLIGATIONS AND CONTRACTS (2002 Ed.), 184.   [26] See CIVIL CODE, Art. 1222.   [27] Id.   [28] De Leon v. Court of Appeals, 432 Phil. 775 (2002). [29] Id. [30] Id. at 788.         [31] Art. 1217. Payment made by one of the solidary debtors extinguishes the obligation. If two or more solidary debtors offer to pay, the creditor may choose which offer to accept.   He who made the payment may claim from his co-debtors only the share which corresponds to each, with the interest for the payment already made. If the payment is made before the debt is due, no interest for the intervening period may be demanded.   When one of the solidary debtors cannot, because of his insolvency, reimburse his share to the debtor paying the obligation, such share shall be borne by all his co-debtors, in proportion to the debt of each. (Emphasis supplied).   [32] 412 Phil. 614 (2001).