G.R. No. 178607 - Jimenez vs. Sorongon

Baylon R. BaAez was employed by De La Salle University (DLSU) beginning on July 19, 1967, and served as a Laboratory Technician at the Chemistry Department from January 25, 1991, to August 26, 2006.
His assigned duties included:

Operating and managing the College of Science Chemistry Laboratories and stockrooms.
Preparing and dispensing reagents and other laboratory materials for classes.
Maintaining cleanliness and general order in the stockrooms.
Checking and monitoring the continuous supply of fuel gas.
Facilitating the movement and proper handling of gas order cylinders.
Handling the inventory of laboratory stocks such as chemicals, glassware, apparatus, laboratory consumables, fixtures, and furniture.

Baylon experienced multiple hospital admissions in 2006 due to various health complaints:

From April 9–15, 2006: Hospitalized at Manila Doctors Hospital for fever, weakness, dysuria, and flank pains; diagnosed with urinary tract infection.
On May 18, 2006: Admitted for seven days for functional dyspepsia.
On June 9, 2006: Admitted at the Medical Center Manila for vomiting and weakness; diagnosed with Systemic Lupus Erythematosus (SLE).

On July 30, 2006, Dr. Erle S. Castillo prepared a clinical abstract/toxicologic assessment hinting at the possibility of a chemically induced disease based on his occupational history.
Baylon was readmitted on August 9, 2006, and eventually succumbed to SLE and its complications—Auto-Immune Hemolytic Anemia, SLE Nephritis, SLE Vasculitis, and Thrombocytopenia Secondary to SLE—on August 27, 2006.
On October 30, 2006, Dr. Dennis Torres issued a Medical Certificate suggesting that Baylon's SLE might have been precipitated by chronic chemical exposure in his role as a laboratory technician.

Based on the medical opinions and toxicologic assessment, the petitioner (Estrella D.S. BaAez) filed a claim for death benefits under the Employees' Compensation Law with the Social Security System (SSS).
The SSS denied the claim on September 21, 2007, on two main grounds:

The cause of death (cardiac complication of SLE) was not considered work-related.
SLE was not included in the list of occupational diseases.

The petitioner subsequently appealed the SSS decision before the Employees’ Compensation Commission (ECC), which affirmed the denial on April 4, 2008.
A petition for review was later filed before the Court of Appeals:

The petitioner initially sought a 30-day extension to file her petition due to the absence of counsel and pending assistance from the UP Office of Legal Aid.
The Court of Appeals granted only a 15-day extension, stipulating that the petition must be filed by June 15, 2008.
The petition was eventually filed on July 4, 2008, rendering it untimely.

DLSU argued its non-participation in earlier proceedings and lack of any allegation of responsibility regarding the death benefits.
The inclusion of DLSU was challenged on grounds of lack of proper service and cause of action.

The toxicologic assessment by Dr. Castillo, which indirectly linked chemical exposure with the potential for a chemically induced lupus.
The Medical Certificate by Dr. Torres that suggested a connection between Baylon’s occupational exposure and the onset of SLE.

Establishments that SLE results from a genetic predisposition, usually diagnosed through its clinical presentation and DNA studies.
The toxicologic report failing to conclusively prove a direct causal link between Baylon’s work environment and his SLE.
The differentiation made between SLE and drug-induced lupus, noting that the latter is a temporary and mild condition remedied by cessation of the related drugs.

Whether the petitioner’s delay in filing the petition for review, after the Court of Appeals granted a 15-day extension, amounts to a regulatory violation.
Whether the strict reglementary period applied in the filing of the appeal should be relaxed in the interest of justice despite the petitioner’s circumstances.

Whether substantial evidence exists to establish a work-related causal relationship between Baylon’s exposure to chemicals and his contraction of SLE.
Whether the medical opinions presented, particularly the toxicologic assessment and the Medical Certificate, are sufficient to infer causation given the complex nature of SLE.

Whether DLSU should have been properly impleaded given that it never participated in or was notified of the SSS or ECC proceedings.
Whether the inclusion of DLSU constitutes an incidental error that is both harmless and dismissible on jurisdictional grounds.