6/7/2020 E-Library - Information At Your Fingertips: Printer Friendly The rule on the burden of proof with regard to claims for disability benefits was also reiterated in Dohle-Philman Manning Agency, Inc., et al. v. Heirs of Gazzingan:[85] [T]he 2000 POEA-SEC has created a presumption of compensability for those illnesses which are not listed as an occupational disease. Section 20 (B), paragraph (4) states that "those illnesses not listed in Section 32 of this Contract are disputably presumed as work-related." Concomitant with this presumption is the burden placed upon the claimant to present substantial evidence that his work conditions caused or at least increased the risk of contracting the disease and only a reasonable proof of work-connection, not direct causal relation is required to establish compensability of illnesses not included in the list of occupational diseases.[86] (Citation omitted) The rule that a seafarer must establish the relation between the illness and the nature of work was applied in Teekay Shipping Philippines, Inc. v. Jarin.[87] In Teekay Shipping, Exequiel O. Jarin (Jarin) was hired as Chief Cook onboard the M.T. Erik Spirit. During the term of his employment contract, he was diagnosed with rheumatoid arthritis. Jarin was able to finish his contract and upon return to the Philippines, he immediately reported to Teekay Shipping's office. He was referred to Dr. Christine O. Bocek, a company-designated physician.[88] Jarin was diagnosed with "moon facies and bipedal edema secondary to steroid intake, [rjheumatoid arthritis, resolving and upper respiratory tract infection."[89] He was subsequently referred to Dr. Dacanay, another company-designated physician,[90] who issued a medical report stating that "Jarin's rheumatoid arthritis was not work-related[.]"[91] Jarin filed a complaint for payment of total and permanent disability benefits before the National Labor Relations Commission. [92] He argued in his position paper that his rheumatoid arthritis was related to his work as Chief Cook. He explained that as Chief Cook, he would spend several hours inside the ship's freezer to check the food inventory and to prepare the food for the day. After spending several hours inside the freezer, he would cook dinner. Jarin summarized that the nature of his work exposed him to extremely cold and extremely hot temperatures.[93] This court ruled that Jarin sufficiently proved the relation between his work as Chief Cook and his rheumatoid arthritis, thus granting his claim for disability benefits.[94] In this case, however, petitioner was unable to present substantial evidence to show the relation between her work and the illness she contracted. The record of this case does not show whether petitioner's adenomyoma was pre-existing; hence, this court cannot determine whether it was aggravated by the nature of her employment. She also failed to fulfill the requisites of Section 32-A of the 2000 POEA-SEC for her illness to be compensable, thus, her claim for disability benefits cannot be granted. Petitioner argues that her illness is the result of her "constantly walking upward and downward on board the vessel carrying loads"[95] and that she "acquired her illness on board respondents' vessel during the term of her employment contract with elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/61719 12/26