5/28/2020 E-Library - Information At Your Fingertips: Printer Friendly With respect to the applicable rules, it is doctrinal that the entitlement of seamen on overseas work to disability benefits “is a matter governed, not only by medical findings, but by law and by contract. The material statutory provisions are Articles 191 to 193 under Chapter VI (Disability Benefits) of the Labor Code, in relation [to] Rule X of the Rules and Regulations Implementing Book IV of the Labor Code. By contract, the POEASEC, as provided under Department Order No. 4, series of 2000 of the Department of Labor and Employment, and the parties’ Collective Bargaining Agreement bind the seaman and his employer to each other.”[46] In the foregoing light, the Court observes that respondent executed his contract of employment on July 17, 2000,[47] incorporating therein the terms and conditions of the 2000 POEA-SEC which took effect on June 25, 2000. However, since the implementation of the provisions of the foregoing 2000 POEA-SEC was temporarily suspended [48] by the Court on September 11, 2000, particularly Section 20, paragraphs (A), (B), and (D) thereof, and was lifted only on June 5, 2002, through POEA Memorandum Circular No. 2, series of 2002, [49] the determination of respondent’s entitlement to the disability benefits should be resolved under the provisions of the 1996 POEA-SEC as it was, effectively, the governing circular at the time respondent’s employment contract was executed. The prevailing rule under Section 20 (B) of the 1996 POEA-SEC on compensation and benefits for injury or illness was that an employer shall be liable for the injury or illness suffered by a seafarer during the term of his contract. There was no need to show that such injury was work-related except that it must be proven to have been contracted during the term of the contract. The rule, however, is not absolute and the employer may be exempt from liability if he can successfully prove that the cause of the seaman’s injury was directly attributable to his deliberate or willful act as provided under Section 20 (D) thereof, to wit: D. No compensation shall be payable in respect of any injury, incapacity, disability or death of the seafarer resulting from his willful or criminal act, provided however, that the employer can prove that such injury, incapacity, disability or death is directly attributable to seafarer. Hence, the onus probandi falls on the petitioners herein to establish or substantiate their claim that the respondent’s injury was caused by his willful act with the requisite quantum of evidence. In labor cases, as in other administrative proceedings, only substantial evidence or such relevant evidence as a reasonable mind might accept as sufficient to support a conclusion is required.[50] To note, considering that substantial evidence is an evidentiary threshold, the Court, on exceptional cases, may assess the factual determinations made by the NLRC in a particular case. In Career Philippines Shipmanagement, Inc. v. Serna,[51] the Court expressed the elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/56605 5/31