Case Summary (G.R. No. 189574)

Background of the Case

• Estrella D.S. Baez (petitioner) challenges the Court of Appeals' resolution dismissing her petition for death benefits following the death of her husband, Baylon R. Baez.
• Baylon was employed as a Laboratory Technician at De La Salle University (DLSU) from 1967 until his death in 2006.
• His duties included operating chemistry laboratories, preparing reagents, maintaining laboratory cleanliness, and monitoring gas supplies.

Medical History and Cause of Death

• Baylon experienced multiple health issues leading to hospitalizations, including urinary tract infection and Systemic Lupus Erythematosus (SLE).
• He died on August 27, 2006, from complications related to SLE, which included Auto-Immune Hemolytic Anemia and SLE Nephritis.
• Medical certificates from Dr. Erle S. Castillo and Dr. Dennis Torres suggested a possible link between Baylon's chronic exposure to chemicals at work and his illness.

Initial Claim and Denial

• Petitioner filed a claim for death benefits under the Employees' Compensation Law with the Social Security System (SSS), which was denied on the grounds that SLE was not work-related and not listed as an occupational disease.
• The Employees' Compensation Commission (ECC) upheld the SSS's denial, stating that SLE is caused by genetic factors rather than occupational exposure.

Appeal Process and Court of Appeals' Ruling

• Petitioner appealed the ECC's decision to the Court of Appeals, requesting an extension to file her petition due to the absence of legal counsel.
• The Court of Appeals granted a 15-day extension, but the petition was ultimately filed late, leading to its dismissal for being out of time.

Arguments Presented by Petitioner

• Petitioner argued that her husband's work as a laboratory technician, involving chronic exposure to chemicals, could have contributed to his illness and death.
• She presented medical opinions as substantial evidence to support her claim, asserting that the ECC should not have dismissed her case based solely on the nature of the illness.

Respondents' Positions

• DLSU contended that it was not involved in the proceedings and had not been served any summons regarding the claim.
• The SSS defended the dismissal, emphasizing the importance of adhering to procedural rules regarding the timeliness of appeals and asserting that no causal relationship was established between Baylon's employment and his illness.

Legal Principles on Appeals

• The court reiterated that the perfection of an appeal is a jurisdictional requirement, and failure to comply with the prescribed period renders the decision final and executory.
• While there are instances where the court may relax rules for substantial justice, no compelling reason was found to justify the late filing in this case.

Findings on Causal Relationship

• For the claim to succeed, substantial evidence m...continue reading

Case Syllabus (G.R. No. 189574)

Background of the Case

• Estrella D. S. BaAez (petitioner) filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court against the Social Security System (SSS) and De La Salle University (DLSU) regarding the denial of her claim for death benefits.
• The case centers around the death of her husband, Baylon R. BaAez, who worked as a Laboratory Technician at DLSU from 25 January 1991 until his death on 27 August 2006.

Employment and Medical History

• Baylon was employed at DLSU since 19 July 1967 and had varied responsibilities that involved handling laboratory materials and monitoring chemical supplies.
• His health deteriorated starting from April 2006, leading to multiple hospitalizations diagnosed with various conditions, culminating in a diagnosis of Systemic Lupus Erythematosus (SLE).
• Doctors noted the potential for a chemically induced illness, with specific mention of occupational hazards during his employment.

Death and Initial Claim Denial

• Baylon died from complications related to SLE, which included Auto-Immune Hemolytic Anemia and SLE Nephritis.
• Following his death, Estrella filed a claim for death benefits under the Employees’ Compensation Law, which was initially denied by the SSS on the grounds that SLE was not work-related and not listed as an occupational disease.

Appeal to the Employees' Compensation Commission (ECC)

• The SSS's denial was upheld by the ECC on 4 April 2008, which de...continue reading