8/20/2020 E-Library - Information At Your Fingertips: Printer Friendly Underlying cause: c. SEC. TO PROSTATE CA Under the given definition of the 2000 POEA-SEC, a work-related illness is "any sickness resulting to disability or death as a result of an occupational disease listed under Section 32-A of this contract with the conditions set therein satisfied."[32] The 2000 POEA-SEC creates a disputable presumption that illnesses not mentioned therein are work-related.[33] However, on the ground of due process, the claimant may still prove by substantial evidence, or that amount of relevant evidence which a person might accept as adequate to justify a conclusion, that the seafarer's work conditions caused or, at least, increased the risk of contracting the disease. This is because awards of compensation cannot rest entirely on bare assertions and presumptions;[34] substantial evidence is required to prove the concurrence of the conditions that will merit compensability, consistent with the liberal interpretation accorded the provisions of the Labor Code and the social justice guarantee in favor of the workers.[35] In the present case, Teodolah was able to prove through substantial evidence the causal connection between Eduardo's work as a seafarer and his cause of death. Evidence substantiating the same included an enumeration of Eduardo's exposure to chemicals, noise and whole-body vibrations, strong draft winds and stormy weather, cold stress and heat stress, excessive heat from burners and steam pipes, and ultraviolet radiation during welding operations while on board and in the exercise of his duties as a Second Officer for petitioners. In point of fact, Teodolah already established the causal link between the nature of Eduardo's work and the cause of the deterioration of his health leading to his repatriation at the first instance in her complaint[36] before the Labor Arbiter. There, she contended, among others, that after his repatriation, a physician at the Lung Center of the Philippines diagnosed him then to have been suffering from bronchial asthma, which was chemical-induced. These claims were not dispelled by the Labor Arbiter but were merely disregarded on the reasoning that Eduardo's death was not compensable because it occurred after the expiration of his employment contract.[37] Upon full consideration of the evidence presented by Teodolah, the CA correctly found that there is at least reasonable correlation established between the nature of Eduardo's work and the cause of his death. Under settled jurisprudence, reasonable correlation is all that is required to prove a rightful claim for death benefits. In the early case of Iloilo Dock & Engineering Co. v. Workmen's Compensation Commission,[38] this Court has already made the pronouncement that the question of compensation coverage necessarily revolves around the core requirement of workconnection, and the corresponding evidence that establishes it.[39] This Court has also taken the early occasion to qualify that when it comes to evaluating work-relatedness with respect to its guiding provisions in labor laws and their implementing rules, the same must always be construed fairly, reasonably, or liberally in favor, or for the elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/64957 4/9