In a contract of carriage, common carriers are presumed negligent if a passenger dies or is injured. This case clarifies that certifications from foreign government agencies like USAID are considered public documents, admissible in Philippine courts without requiring authentication. Such documents are considered prima facie evidence, and the burden falls on the opposing party to present clear and convincing evidence to dispute the facts stated therein.

Death on a Taxicab: When is a Foreign Agency’s Certification Admissible in Court?

This case stems from a tragic incident where Jose Marcial K. Ochoa died while riding a taxicab operated by G & S Transport Corporation, leading to a lawsuit filed by his heirs for damages. The Regional Trial Court (RTC) initially found G & S liable for breach of contract of carriage, awarding damages including loss of earning capacity based on a certification issued by the United States Agency for International Development (USAID), Ochoa’s employer. However, the Court of Appeals (CA) partially reversed this decision, questioning the admissibility of the USAID certification and reducing the amount of moral damages. The Supreme Court (SC) then took up the consolidated petitions to resolve the admissibility of the USAID certification and determine the appropriate damages.

The central issue before the Supreme Court was whether the USAID certification, submitted to prove Ochoa’s income and thus determine the loss of earning capacity, was admissible as evidence without further authentication. G & S Transport argued that the certification was a private document and should have been authenticated by the signatory, Jonas Cruz, to be admissible. The heirs of Ochoa, on the other hand, contended that the certification was a public document and thus did not require authentication. The resolution of this issue hinged on whether the USAID certification could be classified as a public document under the Rules of Court.

The Supreme Court emphasized the distinction between public and private documents as outlined in Section 19, Rule 132 of the Rules of Court. It stated that public documents include “written official acts, or records of the official acts of the sovereign authority, official bodies and tribunals, and public officers, whether of the Philippines, or of a foreign country.” The Court then examined the nature of USAID, noting its status as a principal agency of the United States government responsible for extending assistance to various countries. Given this status, the Court concluded that USAID is an official government agency of a foreign country and, therefore, its documents could be considered public.

Furthermore, the Court reasoned that Jonas Cruz, as the Chief of the Human Resources Division at USAID Philippines, was a public officer. His issuance of the USAID certification was an act performed in his official capacity. Consequently, the USAID certification fell under the definition of a public document under the Rules of Court. The legal implication of classifying the USAID certification as a public document is that its authenticity and due execution are presumed; therefore, it is admissible in court without further proof. This principle is supported by jurisprudence, which holds that public documents are admissible without further proof of their due execution or genuineness.

Sec. 23. Public documents as evidence. – Documents consisting of entries in public records made in the performance of a duty by a public officer are prima facie evidence of the facts therein stated. All other public documents are evidence, even against a third person, of the fact which gave rise to their execution and of the date of the latter.

The Court emphasized that, as a public document issued in the performance of a duty by a public officer, the USAID certification is prima facie evidence of the facts stated within it. This means that the document is presumed to be truthful and accurate unless proven otherwise. The burden then shifts to the opposing party, in this case, G & S Transport, to present clear and convincing evidence to overcome this presumption. The Supreme Court found that G & S Transport failed to provide such evidence, thus affirming the RTC’s decision to admit the USAID certification as evidence of Jose Marcial Ochoa’s income.

In addition to the issue of the USAID certification, the Court addressed G & S Transport’s claim that it had exercised the diligence of a good father of a family in the selection and supervision of its employees, particularly the driver of the taxicab involved in the incident. The Court dismissed this argument as a mere rehash of previous claims that had already been considered and rejected in the earlier decision. The presumption that a common carrier is at fault or negligent when a passenger dies or is injured remained in effect because G & S Transport did not present compelling evidence to the contrary. This highlights the high standard of care expected of common carriers under Philippine law.

However, the Supreme Court also addressed the award of attorney’s fees and costs of litigation. Citing the case of Mercury Drug Corporation v. Baking, the Court reiterated that the reasons or grounds for awarding attorney’s fees must be explicitly stated in the decision. In this case, the lower court’s decision did not provide any factual or legal justification for these awards, merely mentioning them in the dispositive portion. Therefore, the Supreme Court deleted the awards for attorney’s fees and costs of litigation, emphasizing the importance of providing a clear basis for such awards in court decisions.

FAQs

What was the key issue in this case?	The main issue was whether a certification from USAID, a foreign government agency, could be admitted as evidence in a Philippine court without further authentication. The court determined it was a public document and thus admissible.
What is a public document under the Rules of Court?	According to Section 19, Rule 132 of the Rules of Court, a public document includes written official acts or records of official acts of sovereign authority, official bodies, tribunals, and public officers, whether of the Philippines or a foreign country.
Why was the USAID certification considered a public document?	The USAID is an official agency of the United States government, and the certification was issued by a public officer (Chief of Human Resources) in the performance of his official duties, thereby classifying it as a public document.
What is the legal effect of a document being classified as public?	Public documents are admissible in evidence without further proof of their due execution or genuineness. They are presumed authentic and accurate unless proven otherwise.
What does prima facie evidence mean?	Prima facie evidence means that the evidence is sufficient to establish a fact or raise a presumption unless disproved or rebutted. In this case, the USAID certification was prima facie evidence of Ochoa’s income.
What is the standard of diligence required of common carriers?	Common carriers are required to exercise extraordinary diligence in ensuring the safety of their passengers. They are presumed negligent if a passenger dies or is injured.
Why were the attorney’s fees and costs of litigation deleted in this case?	The awards were deleted because the lower court’s decision did not provide any factual or legal justification for granting them, as required by established jurisprudence.
What was the significance of the diligence of a good father of a family argument?	G & S Transport argued it exercised due diligence in hiring and supervising its driver. However, the court found that they failed to present sufficient evidence to overturn the presumption of negligence against a common carrier in the event of a passenger’s death.

This case underscores the importance of proper documentation and the admissibility of evidence in court proceedings, particularly in cases involving contracts of carriage and claims for damages. It clarifies that certifications from foreign government agencies, like USAID, can be admitted as public documents without need for authentication, provided they meet the criteria set forth in the Rules of Court. Parties relying on such documents should be prepared to defend their authenticity, while opposing parties must present clear and convincing evidence to challenge their validity.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: HEIRS OF JOSE MARCIAL K. OCHOA VS G & S TRANSPORT CORPORATION, G.R. No. 170071 & G.R. No. 170125, July 16, 2012