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GR No. 188638

2015-12-09

PHILIPPINE TRANSMARINE CARRIERS v. JOSELITO A. CRISTINO

PEREZ, J.

Here, the respondent did not just rely on the presumption of work-relation but was able to substantiate the claims for compensation and benefits by substantial evidence. Substantial evidence is that amount of "relevant evidence [which] a reasonable mind might accept as adequate to support a conclusion."[61] It is that degree of proof required to support claims for compensation in labor cases.[62]

GR No. 198408

2014-11-12

CONCHITA J. RACELIS v. UNITED PHILIPPINE LINES

PERLAS-BERNABE, J.

While it is true that Brainstem (pontine) Cavernous Malformation is not listed as an occupational disease under Section 32-A of the 2000 POEA-SEC, Section 20 (B) (4) of the same explicitly provides that "[t[he liabilities of the employer when the seafarer suffers work-related injury or illness during the term of his contract are as follows: (t)hose illnesses not listed in Section 32 of this Contract are disputably presumed as work related." In other words, the 2000 POEA-SEC "has created a disputable presumption in favor of compensability[,] saying that those illnesses not listed in Section 32 are disputably presumed as work-related. This means that even if the illness is not listed under Section 32-A of the POEA-SEC as an occupational disease or illness, it will still be presumed as work-related, and it becomes incumbent on the employer to overcome the presumption."[52] This presumption should be overturned only when the employer's refutation is found to be supported by substantial evidence,[53] which, as traditionally defined is "such relevant evidence as a reasonable mind might accept as sufficient to support a conclusion."[54] As held in the case of Magsaysay Maritime Services v. Laurel:[55]

GR No. 200566

2014-09-17

JEBSEN MARITIME INC. v. WILFREDO E. RAVENA

BRION, J.

In Cootauco v. MMS Phil. Maritime Services, Inc.,[30] we categorically declared that whoever claims entitlement to the benefits provided by law should establish his rights to the benefits by substantial evidence.[31] We reiterated this ruling in Wallem Maritime Services, Inc. v. Tanawan,[32] Andrada v. Agemar Manning Agency, Inc.,[33] Crew and Ship Management International Inc. v. Soria,[34] Philman Marine Agency, Inc. v. Cabanban,[35] and Manota v. Avantgarde Shipping Corporation,[36] to name a few. In the case of a seafarer claiming entitlement to disability benefits under the provisions of the POEA-SEC, this burden of proof obviously lies with the seafarer.

GR No. 178564

2014-01-15

INC SHIPMANAGEMENT v. ALEXANDER L. MORADAS

PERLAS-BERNABE, J.

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 following view: Accordingly, we do not re-examine conflicting evidence, re- evaluate the credibility of witnesses, or substitute the findings of fact of the NLRC, an administrative body that has expertise in its specialized field. Nor do we substitute our "own judgment for that of the tribunal in determining where the weight of evidence lies or what evidence is credible." The factual findings of the NLRC, when affirmed by the CA, are generally conclusive on this Court.

GR No. 204076

2013-12-04

JEBSENS MARITIME v. ELENO A. BABOL

MENDOZA, J.

The well-entrenched rule in this jurisdiction is that only questions of law may be entertained by this Court in a petition for review on certiorari under Rule 45. This rule, however, is not absolute and admits certain exceptions, such as when the petitioner persuasively alleges that there is insufficient or insubstantial evidence on record to support the factual findings of the tribunal or court a quo,[12] as Section 5, Rule 133 of the Rules of Court states in express terms that in cases filed before administrative or quasi-judicial bodies, a fact may be deemed established only if supported by substantial evidence.[13]

GR No. 188595

2013-08-28

SEA POWER SHIPPING ENTERPRISES v. NENITA P. SALAZAR

SERENO, C.J.

In compensation proceedings for seafarers, this Court refers to the provisions of the POEA Contract as it memorializes the minimum rights of a seafarer and the concomitant obligations of an employer.[27] Section 20(A) thereof pertinently discusses the rules on granting death benefits. Nevertheless, on account of the liberal interpretation permeating seafarer's agreements,[28] we also consider the possibility of compensation for the death of the seafarer under Section 32-A of the POEA Contract.

GR No. 160444

2012-08-29

WALLEM MARITIME SERVICES v. ERNESTO C. TANAWAN

BERSAMIN, J.

It is the oft-repeated rule, however, that whoever claims entitlement to the benefits provided by law should establish his right to the benefits by substantial evidence.[45] As such, Tanawan must present concrete proof showing that he acquired or contracted the injury or illness that resulted to his disability during the term of his employment contract.[46] Proof of this circumstance was particularly crucial in view of his non-reporting of the injury to the petitioner. Yet, he did not present any proof of having sustained the eye injury during the term of his contract. All that he submitted was his bare allegation that his eye had been splashed with some thinner while he was on board the vessel. He also did not adduce any proof demonstrating that the splashing of thinner could have caused the retinal detachment with vitreous hemorrhage. At the very least, he should have adduced proof that would tie the accident to the eye injury. We note at this juncture that even the certification by Dr. Bunuan provided no information on the possible cause of the eye injury.

GR No. 173951

2012-04-16

DANIEL M. ISON v. CREWSERVE

DEL CASTILLO, J.

In sum, we hold that the CA did not err in denying petitioner's claim for disability compensation as no adequate and credible evidence was submitted to show entitlement to the same. As we have consistently held, awards for compensation cannot be made to rest on mere speculations and presumptions.[38]

GR No. 192558

2012-02-15

BITOY JAVIER v. FLY ACE CORPORATION

MENDOZA, J.

In sum, the rule of thumb remains: the onus probandi falls on petitioner to establish or substantiate such claim by the requisite quantum of evidence.[32] "Whoever claims entitlement to the benefits provided by law should establish his or her right thereto x x x."[33] Sadly, Javier failed to adduce substantial evidence as basis for the grant of relief.

GR No. 191491

2011-12-14

JEBSENS MARITIME INC. v. ENRIQUE UNDAG

MENDOZA, J.

In labor cases as in other administrative proceedings, substantial evidence or such relevant evidence as a reasonable mind might accept as sufficient to support a conclusion is required. The oft-repeated rule is that whoever claims entitlement to the benefits provided by law should establish his or her right thereto by substantial evidence.[5] Substantial evidence is more than a mere scintilla. The evidence must be real and substantial, and not merely apparent; for the duty to prove work-causation or work-aggravation imposed by law is real and not merely apparent.[6]

GR No. 191491

2011-12-14

JEBSENS MARITIME INC. v. ENRIQUE UNDAG

MENDOZA, J.

The Court's ruling is not novel. In the past, the Court repeatedly denied the payment of disability benefits to seamen who failed to comply with the mandatory reporting and examination requirement. Lately, in the recent case of Alex C. Cootauco v. MMS Phil. Maritime Services, Inc.,[11] it was written: For this purpose, the seafarer shall submit himself to a post-employment medical examination by a company-designated physician within three working days upon his return except when he is physically incapacitated to do so, in which case a written notice to the agency within the same period is deemed as compliance. Failure of the seafarer to comply with the mandatory reporting requirement shall result in his forfeiture of the right to claim the above benefits.

	GR No. 188638 2015-12-09	PHILIPPINE TRANSMARINE CARRIERS v. JOSELITO A. CRISTINO PEREZ, J.
Here, the respondent did not just rely on the presumption of work-relation but was able to substantiate the claims for compensation and benefits by substantial evidence. Substantial evidence is that amount of "relevant evidence [which] a reasonable mind might accept as adequate to support a conclusion."[61] It is that degree of proof required to support claims for compensation in labor cases.[62]
	GR No. 198408 2014-11-12	CONCHITA J. RACELIS v. UNITED PHILIPPINE LINES PERLAS-BERNABE, J.
While it is true that Brainstem (pontine) Cavernous Malformation is not listed as an occupational disease under Section 32-A of the 2000 POEA-SEC, Section 20 (B) (4) of the same explicitly provides that "[t[he liabilities of the employer when the seafarer suffers work-related injury or illness during the term of his contract are as follows: (t)hose illnesses not listed in Section 32 of this Contract are disputably presumed as work related." In other words, the 2000 POEA-SEC "has created a disputable presumption in favor of compensability[,] saying that those illnesses not listed in Section 32 are disputably presumed as work-related. This means that even if the illness is not listed under Section 32-A of the POEA-SEC as an occupational disease or illness, it will still be presumed as work-related, and it becomes incumbent on the employer to overcome the presumption."[52] This presumption should be overturned only when the employer's refutation is found to be supported by substantial evidence,[53] which, as traditionally defined is "such relevant evidence as a reasonable mind might accept as sufficient to support a conclusion."[54] As held in the case of Magsaysay Maritime Services v. Laurel:[55]
	GR No. 200566 2014-09-17	JEBSEN MARITIME INC. v. WILFREDO E. RAVENA BRION, J.
In Cootauco v. MMS Phil. Maritime Services, Inc.,[30] we categorically declared that whoever claims entitlement to the benefits provided by law should establish his rights to the benefits by substantial evidence.[31] We reiterated this ruling in Wallem Maritime Services, Inc. v. Tanawan,[32] Andrada v. Agemar Manning Agency, Inc.,[33] Crew and Ship Management International Inc. v. Soria,[34] Philman Marine Agency, Inc. v. Cabanban,[35] and Manota v. Avantgarde Shipping Corporation,[36] to name a few. In the case of a seafarer claiming entitlement to disability benefits under the provisions of the POEA-SEC, this burden of proof obviously lies with the seafarer.
	GR No. 178564 2014-01-15	INC SHIPMANAGEMENT v. ALEXANDER L. MORADAS PERLAS-BERNABE, J.
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 following view: Accordingly, we do not re-examine conflicting evidence, re- evaluate the credibility of witnesses, or substitute the findings of fact of the NLRC, an administrative body that has expertise in its specialized field. Nor do we substitute our "own judgment for that of the tribunal in determining where the weight of evidence lies or what evidence is credible." The factual findings of the NLRC, when affirmed by the CA, are generally conclusive on this Court.
	GR No. 204076 2013-12-04	JEBSENS MARITIME v. ELENO A. BABOL MENDOZA, J.
The well-entrenched rule in this jurisdiction is that only questions of law may be entertained by this Court in a petition for review on certiorari under Rule 45. This rule, however, is not absolute and admits certain exceptions, such as when the petitioner persuasively alleges that there is insufficient or insubstantial evidence on record to support the factual findings of the tribunal or court a quo,[12] as Section 5, Rule 133 of the Rules of Court states in express terms that in cases filed before administrative or quasi-judicial bodies, a fact may be deemed established only if supported by substantial evidence.[13]
	GR No. 188595 2013-08-28	SEA POWER SHIPPING ENTERPRISES v. NENITA P. SALAZAR SERENO, C.J.
In compensation proceedings for seafarers, this Court refers to the provisions of the POEA Contract as it memorializes the minimum rights of a seafarer and the concomitant obligations of an employer.[27] Section 20(A) thereof pertinently discusses the rules on granting death benefits. Nevertheless, on account of the liberal interpretation permeating seafarer's agreements,[28] we also consider the possibility of compensation for the death of the seafarer under Section 32-A of the POEA Contract.
	GR No. 160444 2012-08-29	WALLEM MARITIME SERVICES v. ERNESTO C. TANAWAN BERSAMIN, J.
It is the oft-repeated rule, however, that whoever claims entitlement to the benefits provided by law should establish his right to the benefits by substantial evidence.[45] As such, Tanawan must present concrete proof showing that he acquired or contracted the injury or illness that resulted to his disability during the term of his employment contract.[46] Proof of this circumstance was particularly crucial in view of his non-reporting of the injury to the petitioner. Yet, he did not present any proof of having sustained the eye injury during the term of his contract. All that he submitted was his bare allegation that his eye had been splashed with some thinner while he was on board the vessel. He also did not adduce any proof demonstrating that the splashing of thinner could have caused the retinal detachment with vitreous hemorrhage. At the very least, he should have adduced proof that would tie the accident to the eye injury. We note at this juncture that even the certification by Dr. Bunuan provided no information on the possible cause of the eye injury.
	GR No. 173951 2012-04-16	DANIEL M. ISON v. CREWSERVE DEL CASTILLO, J.
In sum, we hold that the CA did not err in denying petitioner's claim for disability compensation as no adequate and credible evidence was submitted to show entitlement to the same. As we have consistently held, awards for compensation cannot be made to rest on mere speculations and presumptions.[38]
	GR No. 192558 2012-02-15	BITOY JAVIER v. FLY ACE CORPORATION MENDOZA, J.
In sum, the rule of thumb remains: the onus probandi falls on petitioner to establish or substantiate such claim by the requisite quantum of evidence.[32] "Whoever claims entitlement to the benefits provided by law should establish his or her right thereto x x x."[33] Sadly, Javier failed to adduce substantial evidence as basis for the grant of relief.
	GR No. 191491 2011-12-14	JEBSENS MARITIME INC. v. ENRIQUE UNDAG MENDOZA, J.
In labor cases as in other administrative proceedings, substantial evidence or such relevant evidence as a reasonable mind might accept as sufficient to support a conclusion is required. The oft-repeated rule is that whoever claims entitlement to the benefits provided by law should establish his or her right thereto by substantial evidence.[5] Substantial evidence is more than a mere scintilla. The evidence must be real and substantial, and not merely apparent; for the duty to prove work-causation or work-aggravation imposed by law is real and not merely apparent.[6]
	GR No. 191491 2011-12-14	JEBSENS MARITIME INC. v. ENRIQUE UNDAG MENDOZA, J.
The Court's ruling is not novel. In the past, the Court repeatedly denied the payment of disability benefits to seamen who failed to comply with the mandatory reporting and examination requirement. Lately, in the recent case of Alex C. Cootauco v. MMS Phil. Maritime Services, Inc.,[11] it was written: For this purpose, the seafarer shall submit himself to a post-employment medical examination by a company-designated physician within three working days upon his return except when he is physically incapacitated to do so, in which case a written notice to the agency within the same period is deemed as compliance. Failure of the seafarer to comply with the mandatory reporting requirement shall result in his forfeiture of the right to claim the above benefits.

ALEX C. COOTAUCO v. MMS PHIL. MARITIME SERVICES