Ochoa v. G & S Transport Corporation
REITERATIONFacts
The Antecedents: The heirs of Jose Marcial K. Ochoa filed a Complaint for Damages against G & S Transport Corporation (G & S) due to the death of Jose Marcial while onboard a taxicab owned and operated by G & S. Procedural History: The Regional Trial Court (RTC) found G & S guilty of breach of contract of carriage and ordered it to pay civil indemnity, loss of earning capacity, attorney's fees, and costs. Upon partial reconsideration, the RTC also awarded moral and exemplary damages. The Court of Appeals (CA) affirmed the RTC decision but deleted the award for loss of earning capacity, deeming the income certificate self-serving and unsupported by competent evidence, and reduced moral damages. The Supreme Court, in its March 9, 2011 Decision, affirmed the CA decision with modifications, ordering G & S to pay P6,611,634.59 for loss of earning capacity and P100,000.00 as moral damages. The Petition: G & S filed a Motion for Reconsideration of the Supreme Court's March 9, 2011 Decision, arguing that the USAID Certification used to compute loss of income was inadmissible due to lack of authentication, that it exercised the diligence of a good father of a family, and that the Court should review the facts of the case.
Issue(s)
Whether the USAID Certification is admissible in evidence despite the lack of formal authentication. Whether G & S Transport Corporation exercised the diligence of a good father of a family in the selection and supervision of its employees. Whether the Supreme Court should re-examine the factual findings of the lower courts. Whether the awards for attorney's fees and costs of litigation are proper.
Ruling
The Motion for Reconsideration is denied with finality, except for the deletion of the awards for attorney's fees and costs of litigation.
Ratio Decidendi
On the admissibility of the USAID Certification: The Court reiterated that the requirement of authentication applies only to private documents, not to public documents. The USAID Certification, issued by an official of the United States Agency for International Development (USAID), a foreign government agency, is classified as a public document under Section 19(a), Rule 132 of the Rules of Court. As a public document, its authenticity and due execution are presumed, and it is prima facie evidence of the facts stated therein. G & S failed to present clear and sufficient evidence to overcome these presumptions. Therefore, the RTC correctly admitted the certification as basis for the award of loss of income. On the diligence of a good father of a family: The Court found that G & S's arguments regarding the exercise of diligence were a mere rehash of those already passed upon in its March 9, 2011 Decision. The presumption that a common carrier is at fault or negligent when a passenger dies or is injured was not overcome by G & S. The conclusion that G & S failed to overcome this presumption stands. On re-examining factual findings: The Court reiterated its stance that it is not a trier of facts and does not ordinarily analyze or weigh evidence. While G & S enumerated exceptions to this rule, it failed to specify under which exception its case fell. Upon review of the records, the Court found no compelling reason to deviate from the established principle and disturb the factual findings of the CA. On attorney's fees and costs of litigation: The Court noted that the trial court's decision did not provide any basis or justification for the awards of attorney's fees and costs of litigation, merely stating them in the dispositive portion. Citing established jurisprudence, the Court held that such awards must be stated in the text of the decision with a clear basis. Consequently, these awards were deleted.
Main Doctrine
A certification issued by the United States Agency for International Development (USAID), being an official act of a foreign government agency, is a public document and thus presumed authentic and genuine, not requiring further authentication. Furthermore, a common carrier is presumed negligent when a passenger dies or is injured, and it is incumbent upon the carrier to overcome this presumption by presenting evidence of the utmost diligence of a good father of a family in the selection and supervision of its employees.