6/14/2021 E-Library - Information At Your Fingertips: Printer Friendly on due process grounds, the claimant-seafarer must still prove by substantial evidence that his work conditions caused or, at least, increased the risk of contracting the disease. This is because awards of compensation cannot rest entirely on bare assertions and presumptions. In order to establish compensability of a non­ occupational disease, reasonable proof of work-connection is sufficient - direct causal relation is not required. Thus, probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings.[78] (Citations omitted) A similar ruling was rendered in Heirs of the Late Manalo N Licuanan, represented by his wife Virginia S. Licuanan v. Singa Ship Management, Inc., et al.,[79] where it was elaborated that "[i]t is not required that the employment be the sole factor in the growth, development or acceleration of the illness to entitle the claimant to the benefits incident thereto. It is enough that the employment had contributed, even in a small measure, to the development of the disease."[80] Moreover, in Grieg Philippines, Inc., et al. v. Gonzales;[81] and Lorna B. Diona v. ND Shipping Agency and Allied Services, Inc., Carribean Town and Barge (Pan Ama) Ltd., [82] it was stressed that the seafarer only needs to show a reasonable linkage between his work and the contracted illness that would lead a rational mind to conclude that his occupation contributed to, or aggravated his disease.[83] In other cases, this Court likewise noted additional factors that prove a causal link between the employment and the illness of the seafarer. In Skipper United,[84] the development and the progression of the seafarer's disease during the employment contract were regarded as additional proof of causation.[85] Furthermore, in Aldrine B. Ilustricimo v. NYK-FIL Ship Management, Inc., et al.;[86] and Jebsen Maritime Inc., Tim Oord Shipmanagement B.V. and/or Estanislao Santiago v. Timoteo Gavina,[87] the seafarer's length of service in the same vessel was viewed as a contributing element that exacerbated the seafarer's condition. Additionally, stress, fatigue, and the harsh conditions at sea were considered as contributing factors that aggravated the seafarer's ailment. As held in De Leon v. Maunlad Trans, Inc., et al.:[88] Working on any vessel, whether it be a cruise ship or not, can still expose any employee to harsh conditions. In this case, aside from the usual conditions experienced by seafarers, such as the harsh conditions of the sea, long hours of work, stress brought about by being away from their families, petitioner, a team head waiter, also performed the duties of a 'fire watch' and assigned to welding works, all of which contributed to petitioner's stress, fatigue and extreme exhaustion. To presume, therefore, that employees of a cruise ship do not experience the usual perils encountered by those working on a different vessel is utterly wrong.[89] In Canuel, et al. v. Magsaysay Maritime Corporation, et al.,[90] the Court acknowledged that the seafarer's exposure to the harsh sea weather, chemical irritants, and dust on https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66892 9/23