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[36] 691 Phil. 521 (2012).
[37] Id. at 538-539.
[38] G.R. No. 203472, July 9, 2014, 729 SCRA 631.
[39] POEA Memorandum Circular No. 10, series of 2010, Amended Standard Terms and
Conditions Governing the Overseas Employment of Filipino Seafarers On-Board OceanGoing Ships, October 26, 2010.
Section 20-A(6) provides:
In case of permanent total or partial disability of the seafarer caused by
either injury or illness the seafarer shall be compensated in accordance with
the schedule of benefits enumerated in Section 32 of this Contract.
Computation of his benefits arising from an illness or disease shall be
governed by the rates and the rules of compensation applicable at the time
the illness or disease was contracted.
The disability shall be based solely on the disability gradings provided under
Section 32 of this Contract, and shall not be measured or determined by the
number of days a seafarer is under treatment or the number of days in
which sickness allowance is paid.
[40] Magsaysay Maritime Corporation v. Simbajon, supra note 38, at 652-653.
[41] Rollo, p. 150.
[42] Id. at 30.
[43] G.R. No. 194362, June 26, 2013, 700 SCRA 53.
[44] Supra note 38.
[45] Rollo, p. 84.
[46] Id. at 151.
[47] Id. at 29.
[48] Id. at 147.
[49] Id. at 148.
[50] The straight-leg-raise test (or (Lasegue's sign) is the most sensitive test for lumbar
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