Enriquez v. Isarog Line Transport
REITERATIONFacts
The Antecedents: Sonny Enriquez was a passenger on a bus owned and operated by respondent Isarog Line Transport, Inc. (Isarog Line), driven by Victor Sedenio. The bus collided with another bus owned by Philtranco Service Enterprises, Inc. (Philtranco), driven by Primitivo Aya-ay, resulting in the death of Sonny Enriquez and several other passengers. Procedural History: Sonny's parents, petitioners William and Nelia-Vela Enriquez (the Spouses Enriquez), filed a complaint for damages against Isarog Line, Sedenio, Philtranco, and Aya-ay. The Regional Trial Court (RTC) found all defendants solidarily liable and awarded civil indemnity, unrealized income, moral damages, exemplary damages, and attorney's fees. The Court of Appeals (CA) affirmed the RTC Decision but modified it by deleting the award for unrealized income and awarding temperate damages instead. The Spouses Enriquez filed a motion for partial reconsideration, which the CA denied. The Petition: The Spouses Enriquez filed a Petition for Review with the Supreme Court, assailing the CA's decision to delete the award for unrealized income.
Issue(s)
Whether the Spouses Enriquez are entitled to damages for their son's loss of earning capacity, considering the presented certification from his employer and the lack of objection to it during the trial.
Ruling
The Court GRANTS the petition, SETS ASIDE the Decision of the Court of Appeals, and REINSTATES the Decision of the Regional Trial Court, including the award for loss of earning capacity, with interest.
Ratio Decidendi
On the entitlement to damages for loss of earning capacity: Article 2206 of the Civil Code entitles heirs to indemnity for loss of earning capacity, which is considered actual damages and must be proven by competent evidence. While documentary evidence is typically required, exceptions exist for low-income earners where judicial notice may suffice. In this case, the Spouses Enriquez presented a certification of Sonny's daily wage, which was admitted due to the defense's failure to object during the trial. The CA erred in disregarding this evidence solely because the signatory was not presented. The RTC correctly applied the standard formula for calculating loss of earning capacity, and the award of P1,038,960.00 was therefore reinstated.
Main Doctrine
Compensation for loss of earning capacity, being in the nature of actual damages, must be duly proven by competent proof and the best obtainable evidence, preferably documentary. Evidence not objected to is deemed admitted and may be validly considered by the court.