6/7/2020 E-Library - Information At Your Fingertips: Printer Friendly presence of asbestos dust without proper safety equipment apart from the allegations made by Doroteo in the pleadings. In other words, the evidence of both sides lack the substance required to establish their respective claims. In Sealanes Marine Services, Inc. v. National Labor Relations Commission, we noted that under the 1996 POEA standard contract, proof that the working conditions increased the risk of a disease is not required for a seaman to claim the benefits under his employment contract for the illness acquired by seamen during the course of their employment.[60] Subsequently, the 2000 POEA standard contract was created which specifically required work-relation as a condition for compensation: Under Sec. 20(b), paragraph 6, of the 2000 POEA Amended Standard Terms and Conditions Governing the Employment of Filipino Seafarers on Board Ocean-Going Vessels, viz.: SEC. 20. Compensation and Benefits.— xxxx B. COMPENSATION AND BENEFITS FOR INJURY OR ILLNESS The liabilities of the employer when the seafarer suffers work-related injury or illness during the term of his contract are as follows: xxxx 6. In case of permanent total or partial disability of the seafarer caused by either injury or illness the seafarer shall be compensated in accordance with the schedule of benefits enumerated in Section 32 of this Contract. Computation of his benefits arising from an illness or disease shall be governed by the rates and the rules of compensation applicable at the time the illness or disease was contracted. Evident from the afore-quoted provision is that the permanent total or partial disability suffered by a seafarer during the term of his contract must be caused by work-related illness or injury. In other words, to be entitled to compensation and benefits under said provision, it is not sufficient to establish that the seafarer's illness or injury has rendered him permanently or partially disabled, but 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 for.[61] (Emphases supplied) This is consistent with the logic behind the court's interpretation of the 1996 POEA standard contract, hence several decisions denying compensability due to the illness proving to be pre-existing.[62] The prevailing rule under the 1996 POEA-SEC was that the illness leading to the eventual death of seafarer need not be shown to be workrelated in order to be compensable, but must be proven to have been contracted during the term of the contract and not pre-existing.[63] The evolution of this rule for the 2000 POEA-SEC is that the illness is further required to be work-related, work- caused, or work-aggravated.[64] elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/62954 6/13