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whether his illnesses are work-related and suffered during the term of his contract,
surmise mere possibilities, but definitely not the lenient probability required by law to
be entitled to disability compensation. The probability of work-connection must at least
be anchored on credible information and not merely on uncorroborated self-serving
allegations as bare allegations do not suffice to discharge the required quantum of
proof of compensability.[29]
To be sure, this Court is not unaware of its statements in previous cases, taking judicial
notice of the working environment that seafarers, in general, have to deal with.[30]
Such judicial notice, however, is nothing more than an acknowledgment of the general
perils encountered by seafarers on board the vessel. It does not sufficiently prove
work-relatedness of a particular illness or injury, much less, prove entitlement to
compensation. To reiterate for emphasis, even an established work-related illness, or
one which is listed as occupational, does not entail a conclusion that the resulting
disability is automatically compensable. In such a case, the seafarer, while not needing
to prove the work-relatedness of his illness, bears the burden of proving compliance
with the conditions of compensability under the POEA contract. Failure to do so will
result in the dismissal of his claim.[31] The Court, thus, takes this oppmiunity to clarify
that, despite such acknowledgment of the general working environment of seafarers,
the Court never dispensed with the required substantial evidence to prove
entitlement to disability benefits under the law.
It is plainly observable in the Court's ruling in Leoncio v. MST Marine Services (Phils.),
Inc.,[32] that it did not merely rely upon the judicial notice it took as to the exposure of
seafarers to varying temperatures, harsh weather conditions, and homesickness in
awarding disability benefits. In fact, in said case, the Court concluded that the
claimant-seafarer, hired as a Chief Cook, "proved, by substantial evidence, his right to
be paid the disability benefits he claims." This is so because, as found by the Court, the
claimant seafarer therein was able to clearly show that he had an existing condition
known to his employer, had repeatedly suffered symptoms of his condition on board the
vessel during his more than 18 years of employment with the same employer, and was
medically repatriated therefor, among others.
In Skippers United Pacific, Inc. and/or Ikarian Moon Shipping Co., Ltd. v. Lagne,[33] the
claimant-seafarer was likewise medically repatriated. The Court also found that he was
able to enumerate in detail and prove his duties and responsibilities as an Oiler. He was
also able to prove that he suffered symptoms (pain on his anus, chest pains, and
difficulty in breathing whenever he carries heavy weight and performs laborious tasks
as part of his job) on board the vessel. Thus, the Court reasonably concluded that the
claimant-seafarer was able to meet the required degree of proof, i.e., substantial
evidence, that his illness is compensable as it is work-connected and suffered during
the term of his contract.
The medically-repatriated claimant-seafarer in the case of Fil-Pride Shipping Company,
Inc. v. Balasta,[34] wherein the Court also took judicial notice of the seafarers'
homesickness and exposure to the perils of the sea, alleged in detail and proved his
specific tasks as an Able Seaman, and that he experienced symptoms of his illness
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