POEA rules, regulations should be given retroactive application

We likewise agree with the petitioner that the 1991 POEA Rules and Regulations should be given retroactive application. The position taken by respondent Joson on this issue is tenuous. The said Rules and Regulations, not affecting substantive rights, are clearly procedural in nature. It is settled that procedural laws may be given retroactive effect, there being no vested rights in rules of procedure. [G.R. No. 114132. November 14, 1996]