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was on May 27, 1996. As per the company's policy, the probationary period was from three (3)
months to a maximum of six (6) months. Applying Article 13 of the Civil Code, the probationary
period of six (6) months consists of one hundred eighty (180) days. The Court conforms with
paragraph one, Article 13 of the Civil Code providing that the months which are not designated
by their names shall be understood as consisting of thirty (30) days each. This case, the Labor
Code pertains to 180 days. Also, as clearly provided for in the last paragraph of Article 13, it is
said that in computing a period, the first day shall be excluded and the last day included. Thus,
the one hundred eighty (180) days commenced on May 27, 1996, and ended on November 23,
1996. The termination letter dated November 25, 1996 was served on respondent Paras only at
3:00 a.m. of November 26, 1996. The Court held that by that time, he was actually already a
regular employee of the petitioner under Article 281 of the Labor Code. His position as a
regularized employee is thus secured until further notice.