6/7/2020 E-Library - Information At Your Fingertips: Printer Friendly evidence during the administrative proceedings before the Labor Arbiter and NLRC or even during the proceedings before the Court of Appeals, and petitioners did not offer any explanation at all as to why they are submitting the evidence only on appeal before this Court. Hence, the Court is not inclined to relax the rules in the present case in petitioners' favor. Moreover, in its review of the evidence on record, the Court bears in mind the settled rule that in administrative and quasi-judicial proceedings, substantial evidence is considered sufficient. Substantial evidence is more than a mere scintilla of evidence or relevant evidence as a reasonable mind might accept as adequate to support a conclusion, even if other minds, equally reasonable, might conceivably opine otherwise. [41] It is also a basic rule in evidence that each party must prove his/her affirmative allegations. Since the burden of evidence lies with the party who asserts an affirmative allegation, the plaintiff or complainant has to prove his/her affirmative allegation in the complaint and the defendant or the respondent has to prove the affirmative allegations in his/her affirmative defenses and counterclaim.[42] Petitioner's Illegal Dismissal The Constitutional guarantee of security of tenure extends to Filipino overseas contract workers as the Court declared in Sameer Overseas Placement Agency, Inc. v. Cabiles[43]: Security of tenure for labor is guaranteed by our Constitution. Employees are not stripped of their security of tenure when they move to work in a different jurisdiction. With respect to the rights of overseas Filipino workers, we follow the principle of lex loci contractus. Thus, in Triple Eight Integrated Services, Inc. v. NLRC, this court noted: Petitioner likewise attempts to sidestep the medical certificate requirement by contending that since Osdana was working in Saudi Arabia, her employment was subject to the laws of the host country. Apparently, petitioner hopes to make it appear that the labor laws of Saudi Arabia do not require any certification by a competent public health authority in the dismissal of employees due to illness. Again, petitioner's argument is without merit. First, established is the rule that lex loci contractus (the law of the place where the contract is made) governs in this jurisdiction. There is no question that the contract of employment in this case was perfected here in the Philippines. Therefore, the Labor Code, its implementing rules and regulations, and other laws affecting labor apply in this case. Furthermore, settled is the rule that the courts of elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/64155 16/27