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be chapters regarding the trend of jurisprudence relating to the notice requirements and
how it has changed from time to time and from various economic backgrounds.
Recommendation
The recommendation of the proponent could be considered as a long term goal
because it could only be attained if the Supreme Court would decide a similar case again.
Such would have no certainty and might be subject to further confusion. A better
recommendation would be to establish certain exceptions from the prevailing
jurisprudence on authorized causes by disease. Such exceptions would be applied if
another case is tried before a court containing a similar set of facts. At the least, a DO
could be issued by the DOLE in order to clarify the application of the case in subsequent
cases concerning termination.