Title
Supreme Court
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.

Case Summary (G.R. No. 189574)

Background and Medical History

Baylon was employed at DLSU as a Laboratory Technician from 19 July 1967 to 26 August 2006. His job involved significant exposure to various chemicals in laboratory settings. He experienced multiple health issues before his death in 2006, including infections and a diagnosis of SLE, which ultimately led to his demise on 27 August 2006. Medical experts, including Dr. Erle S. Castillo and Dr. Dennis Torres, opined that his condition could have been exacerbated by his chronic exposure to chemicals. Petitioner based her claim for death benefits on these doctors' assessments.

Denial of Claim by SSS and ECC

On 21 September 2007, the SSS denied the claim based on the assertion that SLE was not work-related under the Employees’ Compensation Law and not listed as an occupational disease. The denial was upheld by the Employees’ Compensation Commission (ECC) in a decision dated 4 April 2008, which elaborated that SLE arises from a genetic predisposition rather than occupational hazards. The petitioner appealed the ECC's decision to the Court of Appeals but faced procedural issues in filing her appeal.

Court of Appeals Proceedings

The Court of Appeals granted the petitioner a limited extension to file her petition, culminating in a denial of her claim on 4 November 2008 as her appeal was deemed to be filed out of time. The petitioner argued that her circumstances, including obtaining legal assistance, warranted a relaxation of procedural rules. However, the Court of Appeals maintained that compliance with the filing timeline is jurisdictional and that failure to adhere to deadlines renders any appeal final and executory.

Rulings on the Merits of the Case

The Supreme Court underscored that appeals are a privilege, not a right, and thus, strict compliance with procedural rules is required. Ideally, once an appeal period lapses, a case cannot be entertained. Furthermore, dependent on the availability of substantial evidence to establish a causal link between Baylon’s SLE and his occupational exposure, the burden lay with the petitioner to demonstrate how working conditions aggravated or led to his illness.

Findings on Causal Connection

The Supreme Court found that while SLE might have some links to chemical exposure, the evidence presented failed to connect this specific case with any recognized occupational diseases or establish that the employment directly caused or exacerbated Baylon's health condition. The toxicological assessments cited by the petitioner did not sufficiently affirm the claim, thus not fulfilling the prerequisite for establishing a compensable relationship between the disease and the emplo

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