4/20/2021
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In Magsaysay Maritime Corporation v. National Labor Relations Commission,[77] this
Court considered that the working condition of the seafarer did not cause or increase
the risk of contracting the illness. In this case, the employer assailed the grant of
disability benefits to the seafarer after he fell ill with lymphoma. The employer argued
that the seafarer's working condition could not have exposed him to carcinogenic fumes
or chemicals because his duties merely involved housekeeping and cleaning.
In granting the employer's petition, this Court found that the employer was able to
prove that the working conditions on board could not have exposed the seafarer to the
risk of contracting lymphoma. The evidence presented by the employer sufficiently
showed that the seafarer's work as an assistant housekeeping manager did not expose
him to anaesthetics or any viral infection in his workplace.[78]
Corollarily, for death arising from work-related illness to be compensable, the claimant
must satisfy the requirements under the provision, which reads:
SECTION 32-A. Occupational Diseases. —
For an occupational disease and the resulting disability or death to be
compensable, all of the following conditions must be satisfied:
1. The seafarer's work must involve the risks described herein;
2. The disease was contracted as a result of the seafarer's exposure to the
described risks;
3. The disease was contracted within a period of exposure and under such
other factors necessary to contract it; and
4. There was no notorious negligence on the part of the seafarer.
Even if the illness was not contracted as a result of exposure to the work's risks, a preexisting illness may be regarded as work-related if it was aggravated by the seafarer's
working conditions.[79]
Further, jurisprudence has settled that in determining work-relatedness, it is not
necessary that the nature of the seafarer's work is the sole cause of the illness. In
Magsaysay Maritime Services v. Laurel:[80]
Settled is the rule that for illness to be compensable, it is not necessary that
the nature of the employment be the sole and only reason for the illness
suffered by the seafarer. It is sufficient that there is a reasonable
linkage between the disease suffered by the employee and his work
to lead a rational mind to conclude that his work may have
contributed to the establishment or, at the very least, aggravation of
any pre-existing condition he might have had.[81] (Emphasis supplied)
Even if the illness is disputably presumed as work-related, a claimant must still present
substantial evidence that the "work conditions caused or at least increased the risk of
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