2 Id. at 121. 3 Id. at 70-77, 79-80. 4 Id. at 39-54. 5 Sometimes November 17, 1998 in some parts of the records. 6 Rollo, pp. 51-54. 7 Id. at 106. 8 Id. at 171. ART. 281. Probationary employment. – Probationary employment shall not exceed six (6) months from the date the employee started working, unless it is covered by an apprenticeship agreement stipulating a longer period. The services of an employee who has been engaged on a probationary basis may be terminated for a just cause or when he fails to qualify as a regular employee in accordance with reasonable standards made known by the employer to the employee at the time of his engagement. An employee who is allowed to work after a probationary period shall be considered a regular employee. 9 10 Alfaro v. Court of Appeals, G.R. No. 140812, 28 August 2001, 363 SCRA 799, 808. 11 See Pascua v. NLRC (Third Division), G.R. No. 123518, 13 March 1998, 287 SCRA 554, 570. 12 Supra, note 9. 13 Otherwise known as the "Migrant Workers and Overseas Filipinos Act of 1995."