Title
Banez vs. Social Security System
Case
G.R. No. 189574
Decision Date
Jul 18, 2014
A laboratory technician’s death from SLE led to a denied compensation claim, as no substantial evidence linked his illness to chemical exposure at work.
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Case Digest (G.R. No. 189574)

Facts:

Employment and Duties:
Baylon R. Bañez, the husband of petitioner Estrella D. S. Bañez, was employed as a Laboratory Technician at De La Salle University (DLSU) from 25 January 1991 to 26 August 2006. His duties included operating chemistry laboratories, preparing reagents, maintaining cleanliness, handling gas cylinders, and managing laboratory inventories.

Medical History:
Baylon was hospitalized multiple times in 2006 for various conditions, including urinary tract infection, functional dyspepsia, and Systemic Lupus Erythematosus (SLE). He passed away on 27 August 2006 due to complications of SLE, including Auto-Immune Hemolytic Anemia, SLE Nephritis, SLE Vasculitis, and Thrombocytopenia.

Medical Opinions:
Dr. Erle S. Castillo and Dr. Dennis Torres, Baylon’s attending physicians, suggested that his chronic exposure to chemicals as a laboratory technician may have precipitated his illness. Dr. Castillo’s toxicologic assessment noted the probability of a chemically induced disease, while Dr. Torres’ medical certificate indicated that chemical exposure was an occupational hazard.

Claims and Denial:
Petitioner filed a claim for death benefits under the Employees’ Compensation Law with the Social Security System (SSS). The SSS denied the claim, stating that SLE is not a work-related illness or listed as an occupational disease. The Employees’ Compensation Commission (ECC) affirmed the denial, emphasizing that SLE is an autoimmune disease with genetic predispositions.

Procedural History:
Petitioner appealed to the Court of Appeals, but her petition was dismissed for being filed out of time. She sought a review before the Supreme Court, arguing that her husband’s chemical exposure contributed to his illness and death.

Issue:

  1. Whether the Court of Appeals erred in dismissing the petition for review for being filed out of time.
  2. Whether Baylon’s death was causally connected to his employment as a laboratory technician.
  3. Whether the inclusion of DLSU as a respondent was proper.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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