4/29/2020 E-Library - Information At Your Fingertips: Printer Friendly Under Section 20.1.4.1[23] of the parties’ AMOSUP/IMEC-CBA for 2004, the respondent shall be entitled to compensation if he suffers permanent disability as a result of a work-related illness while serving on board. The provision further states that the determination of whether an illness is work-related shall be made in accordance with Philippine laws on employees’ compensation.[24] The 2000 POEA-SEC[25] defines “work-related illness” as “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.”[26] In interpreting the said definition, the Court has held that for disability to be compensable under Section 20(B) of the 2000 POEA-SEC,[27] it is not sufficient to establish that the seafarer’s illness or injury has rendered him permanently or partially disabled; it must also be shown that there is a causal connection between the seafarer’s illness or injury and the work for which he had been contracted.[28] The Court has likewise ruled that the list of illnesses/diseases in Section 32-A does not preclude other illnesses/diseases not so listed from being compensable. The POEA-SEC cannot be presumed to contain all the possible injuries that render a seafarer unfit for further sea duties. [29] This is in view of Section 20(B)(4) of the POEA-SEC which states that “[t]hose illnesses not listed in Section 32 of this Contract are disputably presumed as work-related.” Concomitant with such presumption is the burden placed upon the claimant to present substantial evidence that his working conditions caused or at least increased the risk of contracting the disease.[30] Substantial evidence consists of such relevant evidence which a reasonable mind might accept as adequate to justify a conclusion that there is a causal connection between the nature of his employment and his illness, or that the risk of contracting the illness was increased by his working conditions.[31] Only a reasonable proof of work-connection, not direct causal relation is required to establish compensability of a non-occupational disease.[32] Equally relevant to the resolution of the present claim are the following provisions of the POEA-SEC, viz: SECTION 20. COMPENSATION AND BENEFITS (B) COMPENSATION AND BENEFITS FOR INJURY OR ILLNESS xxxx 3. Upon sign-off from the vessel for medical treatment, the seafarer is entitled to sickness allowance equivalent to his basic wage until he is declared fit to work or the degree of permanent disability has been assessed by the company-designated physician but in no case shall this period exceed one hundred twenty (120) days. elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/56025 6/13