[16] Art. 13 (b). [17] Abaca v. Court of Appeals, 290 SCRA 657 (1998), citing Sec. 1 (d) of the Rules Implementing P.D. 1920 promulgated on July 12, 1984. [18] Id., citing Sec. 1, Rule V, Book II of the POEA Rules and Regulations on Overseas Employment promulgated on May 21, 1985. [19] People v. Sanchez, supra; People v. Sadiosa, supra. [20] People v. Saley, supra. [21] Id. [22] People vs. Menil, G. R. No. 115054-66, prom. September 12, 2000. [23] Ibid.