xi[11] G.R. Nos. 81124-26, 23 June 1988, 162 SCRA 541.
xii[12] Original Records, p. 22.
xiii[13] Philippine Overseas Employment Administation/Department of Labor and Employment.
xiv[14] Sec. 3, Rule II, Book V, Rules and Regulations Governing Overseas Employment (also
known as the POEA Rules and Regulations).
xv[15] See Note 10.
xvi[16] See Note 11.
xvii[17] G.R. No. 108433, 15 October 1996, 263 SCRA 174.
xviii[18] Id., p. 183.
xix[19] Librea v. Employees Compensation Commission, G.R. No. 58879, 14 November 1991,
203 SCRA 545, 552; Nemaria v. Employees Compensation Commission, G. R. No. 57889, 28
October 1987, 155 SCRA 166, 173; Medina v. Employees Compensation Commission, G.R. No.
62406, 22 March 1984, 128 SCRA 349, 354-355.
xx[20] Ambrosio Padilla, Revised Rules on Evidence Annotated, Vol. II, 6th Ed. (1994), p. 180.
xxi[21] Singa Ship Management Philippines, Inc. v. NLRC, G.R. No. 119080, 14 April 1998,
288 SCRA 692, 698-699.
xxii[22] (a) In cases of unlawful withholding of wages the culpable party may be assessed
attorneys fees equivalent to ten percent of the amount of wages recovered.
(b) It shall be unlawful for any person to demand or accept, in any judicial or administrative proceedings for the
recovery of the wages, attorneys fees, which exceed ten percent of the amount of wages recovered.
xxiii[23] Attorneys fees in any judicial or administrative proceedings for the recovery of wages
shall not exceed 10% of the amount awarded.
xxiv[24] In the absence of stipulation, attorneys fees and expenses of litigation, other than
judicial costs, cannot be recovered, except: x x x x (7) In actions for the recovery of wages of
household helpers, laborers and skilled workers x x x x
xxv[25] Philippine National Construction Corporation v. NLRC, G.R. No. 107307, 11 August
1997, 277 SCRA 91, 105; Sebuguero v. NLRC, G.R. No. 115394, 27 September 1995, 248
SCRA 532, 548.
xxvi[26] G.R. No. 88694, 11 January 1993, 217 SCRA 16.