occupational diseases, Suarez had to prove that the risk of contracting the disease was increased by the
conditions under which he worked. The evidence must be real and substantial, and not merely
apparent.8 It must constitute a reasonable basis for arriving at a conclusion that the conditions of his
employment caused the disease or that such conditions aggravated the risk of contracting the illness.
Here, Suarez did not present substantial proof that his eye ailment was work-related. Other than his
bare claim that paint droppings accidentally splashed on an eye causing blurred vision, he adduced no
note or recording of the supposed accident. Nor did he present any record of some medical check-up,
consultation, or treatment that he had undergone. Besides, while paint droppings can cause eye
irritation, such fact alone does not ipso facto establish compensable disability. Awards of compensation
cannot rest on speculations or presumptions; Suarez must prove that the paint droppings caused his
blindness.9
The Court is inclined to accept the findings of Dr. Caparas, the company-designated physician, that it
was cataract extraction, not paint droppings that caused Suarez’s ailment. The definitions of the
imputed medical conditions plainly do not indicate work-relatedness.
Thus, posterior subscapsular cataract is the most common abnormality affecting the lens
epithelium.10 Such illness may be age-related or occur as a complication of other conditions such as
intraocular inflammation, steroid administration, vitreoretinal surgery, and trauma and may also be
related to irradiation and systemic conditions such as diabetes mellitus.11 Pseudophakia indicates
presence of artificial intraocular lens (IOL) replacing normal human lens12 and posterior capsule
opacification is the most frequent complication of cataract surgery.13 By their nature, these ailments are
more the result of eye disease than of one’s kind of work.
Besides, even if the Court were to assume that Suarez’s eye ailment was work-related, he still cannot
claim disability benefits since he concealed his true medical condition. The records show that when
Suarez underwent pre-employment medical examination (PEME), he represented that he was merely
wearing corrective lens.14 He concealed the fact that he had a cataract operation in 2005. He told the
truth only when he was being examined at the Medical City on May 18, 2007. This willful concealment of
a vital information in his PEME disqualifies him from claiming disability benefits pursuant to Section
20(E) of the POEA-SEC which provides that "a seafarer who knowingly conceals and does not disclose
past medical condition, disability and history in the pre-employment medical examination constitutes
fraudulent misrepresentation and shall disqualify him from any compensation and benefits."
The CA has no basis in holding that Suarez's PEME is sufficiently exhaustive as to excuse his nondisclosure of a previous cataract operation.15 The fact that he was physically and psychologically
ascertained to be fit for sea duties does not rule out misrepresentation. A PEME is generally not
exploratory in nature, nor is it a totally in-depth and thorough examination of an applicant's medical
condition.16 It does not reveal the real state of health of an applicant. Since it is not exploratory, its
failure to reveal or uncover Suarez's eye disability cannot shield him from the consequences of his willful
concealment.