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[12] Vergara v. Hammonia Maritime Services, Inc., et al., supra note 6, at 908; C.F.
Sharp Crew Management, Inc., et al. v. Taok, 691 Phil. 521, 533 (2012); Jebsen
Maritime, Inc. and/or Alliance Marine Services, Ltd. v. Undag, 678 Phil. 938, 944
(2011).
[13] Vergara v. Hammonia Maritime Services, Inc., et al., supra note 6.
[14] POEA Memorandum Circular No. 09, Series of 2000. Note that per the POEA
Memorandum Circular No. 10, Series of 2010, the POEA amended amending for the
purpose the 2000 POEA-SEC.
[15] Jebsen Maritime, Inc. v. Ravena, supra note 11, at 511-512.
[16] G.R. No. 215471, November 23, 2015, 775 SCRA 342, 352-359. (Emphasis ours).
[17] 150-C Phil. 133 (1972).
[18] Id. at 139.
[19] Note that there is already a 2010 POEA-SEC. The present case, however, is still
governed by the 2000 POEA-SEC as the employment contract was entered into before
2010.
[20] 510 Phil. 332 (2005).
[21] Id. at 340. The respondent therein was unable to work from August 18, 1998 to
February 22, 1999, at the least, or more than 120 days, due to his medical treatment.
[22] Supra note 11, at 912.
[23] 702 Phil. 717 (2013).
[24] G.R. No. 210634, January 14, 2015, 746 SCRA 287.
[25] G.R. No. 203804, April 15, 2015, 755 SCRA 543.
[26] Id., citing Kestrel Shipping Co., Inc. v. Munar, .supra note 23, at 810.
[27] G.R. No. 211882, July 29, 2015, 764 SCRA 430.
[28] Supra note 27, at 453-454. (Emphasis ours)
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