Da Jose v. Angeles
REITERATIONFacts
The Antecedents: A vehicular collision occurred on December 1, 2001, along the Doña Remedios Trinidad Highway in Pulilan, Bulacan, between a Mitsubishi Lancer driven by the late Eduardo Angeles and a Nissan Patrol driven by Francisco Ocampo, with Robert Da Jose as the registered owner of the Nissan Patrol. Eduardo Angeles died due to Hemorrhagic Shock resulting from Blunt Traumatic Injury. Procedural History: A criminal complaint for Reckless Imprudence Resulting in Homicide and Damage to Property was filed against Francisco Ocampo, who was found guilty by the Municipal Trial Court (MTC). During the pendency of the criminal case, the heirs of Eduardo Angeles (respondents) sent a demand letter for damages. Subsequently, respondents filed a civil complaint for damages based on tort against Robert Da Jose and Francisco Ocampo before the Regional Trial Court (RTC). The RTC found Francisco Ocampo reckless and ordered both petitioners to solidarily pay various damages, including ₱500,000.00 for moral damages and ₱50,000.00 for exemplary damages, and awarded indemnity for hospitalization and burial expenses. The Court of Appeals (CA) affirmed the RTC decision with modification, reducing moral and exemplary damages but awarding ₱2,316,000.00 for lost earnings. The Petition: Petitioners seek a review of the CA decision, primarily questioning the award of ₱2,316,000.00 for lost earnings, arguing that the supporting cash vouchers are hearsay evidence and inadmissible.
Issue(s)
Whether the award of ₱2,316,000.00 for lost earnings is supported by competent evidence, and whether the Joint Affidavit and cash vouchers from Glennis Laundry Haus are admissible as evidence. Whether the petition primarily raises a factual issue regarding the probative value of evidence, and if so, whether the Court can review such issues under a petition for certiorari.
Ruling
The petition is granted. The award for loss of earning capacity in the amount of ₱2,316,000.00 is set aside. All other monetary awards are affirmed with modification to include interest at the rate of 6% per annum from the finality of the decision until full payment.
Ratio Decidendi
On the award for lost earnings and admissibility of evidence: The Court held that the award for loss of earning capacity, being in the nature of actual damages, must be duly proven by competent proof and the best obtainable evidence. Generally, documentary evidence is required. While exceptions exist for self-employed individuals earning below the minimum wage or daily wage workers, this case falls under the general rule as the deceased was claimed to have earned significantly more than the minimum wage. The Court found that the cash vouchers from Glennis Laundry Haus, upon which the CA based its award, suffered from the same infirmity as those from other companies, which were disregarded by the CA for lack of proper identification and authentication. Specifically, the Glennis Laundry Haus vouchers were identified by Celine Angeles, who admitted under cross-examination to having no participation in their preparation. Therefore, these vouchers were considered hearsay evidence, lacking probative value, as they were not authenticated by persons with personal knowledge of their due execution. The RTC's ruling that these vouchers have no probative value was thus sustained. Consequently, there was no competent evidence to support the CA's award for loss of earning capacity. On the procedural issue of questions of law: The Court acknowledged that the petition primarily raises a factual issue regarding the probative value of evidence. However, it clarified that such issues can be reviewed under a petition for certiorari if exceptions apply, such as when the findings of the CA conflict with the RTC, or when the CA manifestly overlooked relevant facts. In this case, the Court found that the CA's findings on the admissibility and probative value of the cash vouchers conflicted with the RTC's findings, and that the CA overlooked the fact that Celine Angeles, the witness who identified the vouchers, had no personal knowledge of their preparation. Therefore, the Court deemed it proper to resolve the case on its merits.
Main Doctrine
The award for loss of earning capacity requires competent proof and the best obtainable evidence, typically documentary evidence. Hearsay evidence, such as cash vouchers not identified by persons with personal knowledge of their preparation, lacks probative value and cannot support such an award.