such answer may plead therein a counterclaim or cross-claim. (N.B. This provision is no longer found in the 1997 Rules of Civil Procedure, as amended.) Sec. 9, Rule II, Book VI of the POEA Rules provides that technicalities of law and procedure and the rules obtaining in the courts of law shall not strictly apply to proceedings before the POEA. xviii[18] xix[19] General Baptist Bible College v. NLRC, 219 SCRA 549 (1993). xx[20] Art. 10, Civil Code. xxi[21] Art. 1236, Civil Code.