In Doehle-Philman Manning Agency, Inc., Dohle (IOM) Limited and Capt. Manolo T. Gacutan vs. Henry C. Haro (G.R. No. 206522, 18 April 2016), the Supreme Court ruled that the seafarer must prove that his illness is work-related when such is not classified as an occupational disease under the POEA-Standard Employment Contract.

After the employers denied his claim for disability benefits, seafarer Haro filed for disability benefits before the Labor Arbiter and he insisted that he was relieved of the burden to show the cause of his rights over the disability benefits because his illness is disputably presumed to be work-related. The employers disagreed with Haro and maintained that for illnesses that are not listed as an occupational disease, the seafarer has the burden to prove the causal connection between his work and his illness.

The Supreme Court agreed with the employers and reminded the seafarer not to simply rely on the presumption. For the presumption to be favourable to the seafarer, he must adduce substantial evidence that his work conditions caused, or at least increased the risk of contracting his illness. The failure of the seafarer to elaborate his work duties or even to specify his task as a seafarer rendered it difficult to determine a link between his work and his illness.