In Robert Da Jose and Francisco Ocampo y Angeles v. Celerina R. Angeles, Edward Angelo R. Angeles, and Celine Angeli R. Angeles, the Supreme Court addressed the requirements for proving lost earning capacity in a personal injury case. The Court ruled that cash vouchers, without proper authentication by individuals with personal knowledge of their preparation, constitute inadmissible hearsay evidence. This decision underscores the importance of presenting competent, non-hearsay evidence when claiming damages for lost earning capacity, affecting how personal injury claims are substantiated in Philippine courts.

Proving Financial Loss: When Hearsay Evidence Falls Short in a Fatal Car Accident Case

The case arose from a vehicular collision that resulted in the death of Eduardo Tuazon Angeles. Following the incident, Celerina Angeles, Eduardo’s wife, along with their children, filed a complaint for damages against Robert Da Jose, the owner of the other vehicle, and Francisco Ocampo y Angeles, the driver. The Regional Trial Court (RTC) found Francisco negligent and ordered Robert and Francisco to pay damages. On appeal, the Court of Appeals (CA) affirmed the RTC’s decision but modified the amounts, including an award for lost earnings based on cash vouchers presented as evidence of Eduardo’s income from Glennis Laundry Haus.

The petitioners, Robert and Francisco, appealed to the Supreme Court, questioning the admissibility of the cash vouchers used to calculate the award for lost earnings. They argued that these vouchers constituted hearsay evidence because the individuals who prepared, checked, or approved them were not presented as witnesses. The petitioners emphasized that Celine Angeles, who identified the vouchers, admitted she had no participation in their preparation. This raised a critical issue regarding the application of the hearsay rule in proving damages for loss of earning capacity.

The Supreme Court framed the central issue as whether the CA erred in awarding P2,316,000 for loss of earning capacity based on the Glennis Laundry Haus cash vouchers. To address this, the Court revisited the rules on evidence, particularly the admissibility of hearsay evidence and the standard of proof required for claiming damages for loss of earning capacity. The Court emphasized that, as a general rule, documentary evidence should be presented to substantiate claims for damages for loss of earning capacity. The Court also cited the exceptions, where documentary evidence is not required if the deceased is self-employed earning minimum wage or less. The burden to prove damages for loss of earning capacity rests on the claimant, who must present competent proof of the deceased’s income.

The Court explained that Article 2206 of the Civil Code entitles the heirs of a victim to indemnity for loss of earning capacity, emphasizing that this compensation is awarded not for lost earnings, but for loss of the capacity to earn money. The Court held that indemnification for loss of earning capacity is an actual damage that must be duly proven by competent proof and the best obtainable evidence.

Thus, as a rule, documentary evidence should be presented to substantiate the claim for damages for loss of earning capacity.

The Supreme Court differentiated a question of law from a question of fact by citing the case of Asian Terminals, Inc. v. Simon Enterprises, Inc.:

A question of law exists when the doubt or controversy concerns the correct application of law or jurisprudence to a certain set of facts; or when the issue does not call for an examination of the probative value of the evidence presented, the truth or falsehood of facts being admitted. A question of fact exists when the doubt or difference arises as to the truth or falsehood of facts or when the query invites calibration of the whole evidence considering mainly the credibility of the witnesses, the existence and relevancy of specific surrounding circumstances as well as their relation to each other and to the whole, and the probability of the situation.

The Court found that the cash vouchers from Glennis Laundry Haus were not properly authenticated because the individuals who prepared, checked, or approved them were not presented as witnesses. The Court noted that it was Celine who identified the vouchers, and she admitted under cross-examination that she had no participation in their preparation. Therefore, the Court deemed the cash vouchers as hearsay evidence, possessing no probative value, thereby affirming the RTC’s ruling on this matter.

The Court defined hearsay evidence and its inadmissibility in court.

Evidence is hearsay when its probative force depends on the competency and credibility of some persons other than the witness by whom it is sought to be produced.

The Court explained that the exclusion of hearsay evidence is anchored on three reasons: absence of cross-examination, absence of demeanor evidence, and absence of oath. The Supreme Court explained the importance of the witness’s personal knowledge of the facts in question.

The Court stated that a witness can only testify on facts within their personal knowledge, and that a document offered as proof of its contents must be authenticated by a person with personal knowledge of the facts stated in the document.

Basic under the rules of evidence is that a witness can only testify on facts within his or her personal knowledge.

Based on the above analysis, the Supreme Court granted the petition, setting aside the CA’s award for loss of earning capacity. The Court affirmed the other monetary awards, including civil indemnity, actual damages, moral damages, exemplary damages, and attorney’s fees. The Supreme Court also modified the ruling to impose an interest of 6% per annum on the amounts awarded from the time of finality of the decision until full payment, citing Del Carmen, Jr. v. Bacoy and Eastern Shipping Lines, Inc. v. Court of Appeals.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals erred in awarding damages for lost earning capacity based on cash vouchers that were considered hearsay evidence. The Supreme Court needed to determine the admissibility and probative value of these documents.
What is hearsay evidence?	Hearsay evidence is evidence whose probative value depends on the credibility of someone other than the witness testifying in court. It is generally inadmissible because the person making the statement is not available for cross-examination.
Why were the cash vouchers considered hearsay?	The cash vouchers were considered hearsay because the individuals who prepared, checked, or approved them were not presented as witnesses to authenticate them. The witness who identified them admitted she had no participation in their preparation.
What type of evidence is required to prove loss of earning capacity?	Generally, documentary evidence, such as income tax returns or employment contracts, should be presented to substantiate a claim for damages for loss of earning capacity. In some cases, testimonial evidence may be sufficient if the deceased earned less than the minimum wage.
What is the effect of failing to present competent evidence of income?	If a claimant fails to present competent evidence of income, the court may not award damages for loss of earning capacity. The claimant bears the burden of proving the deceased’s income with credible and admissible evidence.
What other damages were awarded in this case?	Besides the disallowance of the award for loss of earning capacity, the Court affirmed the awards for civil indemnity, actual damages (hospitalization and burial expenses), moral damages, exemplary damages, and attorney’s fees.
What is the significance of Article 2206 of the Civil Code in this case?	Article 2206 of the Civil Code provides that the heirs of a victim are entitled to indemnity for loss of earning capacity. However, this indemnity must be proven by competent evidence.
What was the final ruling of the Supreme Court?	The Supreme Court granted the petition, setting aside the award for loss of earning capacity but affirming all other monetary awards. The Court also imposed an interest rate of 6% per annum on the total amount awarded from the finality of the decision until full payment.

This case underscores the importance of presenting credible and admissible evidence when claiming damages for loss of earning capacity. The decision serves as a reminder to litigants to ensure that documentary evidence is properly authenticated and that witnesses with personal knowledge of the facts are presented to testify. This evidentiary standard is essential in personal injury cases where financial losses are sought as compensation.

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: ROBERT DA JOSE AND FRANCISCO OCAMPO Y ANGELES, VS. CELERINA R. ANGELES, EDWARD ANGELO R. ANGELES ANDCELINE ANGELI R. ANGELES, G.R. No. 187899, October 23, 2013