In the case of Robert Da Jose and Francisco Ocampo y Angeles vs. Celerina R. Angeles, Edward Angelo R. Angeles and Celine Angeli R. Angeles, the Supreme Court clarified the standards for proving loss of earning capacity in tort cases. The Court held that claims for loss of earning capacity must be supported by competent evidence, particularly when the deceased’s income is above minimum wage. This ruling emphasizes the importance of presenting credible, non-hearsay evidence to substantiate claims for damages, ensuring fairness and accuracy in compensation.

The Case of the Fatal Collision: Can Hearsay Evidence Justify Lost Earnings?

The case arose from a tragic vehicular collision that resulted in the death of Eduardo Tuazon Angeles. Following the incident, his family sought damages from Robert Da Jose, the owner of the other vehicle, and Francisco Ocampo y Angeles, the driver. The Regional Trial Court (RTC) initially ruled in favor of the family, awarding damages, but the Court of Appeals (CA) modified the decision, increasing the award to include compensation for Eduardo’s lost earning capacity. This increase was based on cash vouchers from Glennis Laundry Haus, one of Eduardo’s business ventures. However, the Supreme Court ultimately addressed the question of whether these cash vouchers constituted admissible evidence, thereby influencing the compensation for lost earnings.

The heart of the legal matter revolved around the admissibility of the cash vouchers presented as proof of Eduardo’s income from Glennis Laundry Haus. The petitioners, Da Jose and Ocampo, argued that these vouchers were hearsay evidence, lacking proper authentication since the individuals who prepared them were not presented as witnesses. This argument centered on the fundamental principle that evidence presented in court must be reliable and subject to cross-examination to ensure its validity. The Supreme Court weighed this against the CA’s decision, which had considered the vouchers as sufficient evidence to justify the award for lost earning capacity.

The Supreme Court examined the nature of the evidence and the testimonies provided. It noted that while Celine Angeles, Eduardo’s daughter, identified the cash vouchers, she admitted to having no direct involvement in their preparation. The court emphasized that evidence is considered hearsay when its probative value relies on the credibility of someone other than the witness testifying. This principle is crucial because it ensures that evidence is tested for accuracy and reliability through cross-examination, a cornerstone of the adversarial legal system. The absence of such verification renders the evidence less trustworthy.

“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 exclusion of hearsay evidence is anchored on three reasons: (1) absence of cross-examination; (2) absence of demeanor evidence; and (3) absence of oath.”

The Supreme Court highlighted the importance of establishing a solid foundation for claims of lost earning capacity. Article 2206 of the Civil Code addresses the compensation for death caused by a crime or quasi-delict, stating that the defendant is liable for the loss of the earning capacity of the deceased. However, the Court emphasized that such claims must be substantiated by competent proof, ideally through documentary evidence. While exceptions exist for self-employed individuals earning less than the minimum wage, or daily wage workers, this case did not fall under those exceptions, as Eduardo’s claimed income was significantly higher.

Building on this principle, the Court differentiated its approach from that of the Court of Appeals, which had given weight to the Glennis Laundry Haus cash vouchers. The Supreme Court noted that the RTC had correctly observed the absence of the voucher’s authors as witnesses, a point underscored by the fact that the CA itself disregarded similar vouchers from other entities due to authentication issues. This discrepancy highlighted the need for consistency in evaluating evidence and adhering to the rules of admissibility. The Court emphasized that disregarding these requirements could lead to unreliable and unjust outcomes.

The court then contrasted the requirements for documentary evidence with the testimony presented. It reiterated that a witness can only testify about facts within their personal knowledge. When a document is offered as proof of its contents, it must be authenticated by someone with personal knowledge of the facts stated therein. Since Celine Angeles lacked direct involvement in the preparation of the cash vouchers, her testimony could not sufficiently authenticate them. This distinction between direct and indirect knowledge is fundamental to ensuring that only reliable evidence is considered in legal proceedings.

The ruling emphasized the necessity for parties to present the best obtainable evidence to support their claims. In cases involving significant income, documentary evidence such as financial statements, tax returns, or employment contracts are typically expected. The absence of such evidence raises doubts about the validity of the claimed income and can undermine the claim for loss of earning capacity. By setting this standard, the Supreme Court reinforced the need for diligence and thoroughness in presenting evidence in court.

However, it’s important to note that the court did uphold other damages awarded by the lower courts, including civil indemnity, actual damages for hospitalization and burial expenses, and attorney’s fees. These awards were deemed consistent with prevailing jurisprudence and adequately supported by the evidence presented. In addition, the Court imposed an interest of 6% per annum on the awarded amounts from the date of the decision’s finality until full payment, in accordance with established legal principles. This detail underscores that while the claim for lost earning capacity failed due to evidentiary shortcomings, the plaintiffs were still entitled to other forms of compensation.

The Supreme Court’s decision also serves as a practical guide for legal practitioners and individuals involved in similar cases. It underscores the importance of meticulously gathering and presenting evidence to support claims for damages. Specifically, it highlights the need to authenticate documentary evidence through witnesses with direct knowledge of the documents’ preparation and content. This emphasis on proper authentication can significantly impact the outcome of a case, particularly when substantial damages, such as those for loss of earning capacity, are being claimed.

FAQs

What was the key issue in this case?	The primary issue was whether cash vouchers presented as evidence of the deceased’s income were admissible to prove loss of earning capacity, considering they were deemed hearsay. The Supreme Court assessed whether these vouchers met the standard of competent evidence required for such claims.
What is hearsay evidence?	Hearsay evidence is testimony or documents quoted from people who are not present in court. This type of evidence is generally inadmissible because the person who made the statement cannot be cross-examined to verify its accuracy.
Why was the loss of earning capacity claim denied?	The claim was denied because the cash vouchers used to prove the deceased’s income were considered hearsay. The individuals who prepared the vouchers did not testify in court, making the vouchers inadmissible as competent evidence.
What type of evidence is needed to prove loss of earning capacity?	Ideally, documentary evidence such as income tax returns, employment contracts, or financial statements is needed. This type of evidence provides a reliable basis for calculating the potential earnings lost due to the death or injury of an individual.
What did Article 2206 of the Civil Code provide in relation to this case?	Article 2206 stipulates that in cases of death caused by a crime or quasi-delict, the defendant is liable for the loss of the earning capacity of the deceased. However, it also implies that such claims must be properly substantiated with evidence.
Did the family receive any compensation at all?	Yes, the family received civil indemnity, actual damages for hospitalization and burial expenses, and attorney’s fees. Only the award for loss of earning capacity was set aside due to insufficient evidence.
What is the significance of the best obtainable evidence rule?	The best obtainable evidence rule requires parties to present the most reliable evidence available to support their claims. In this case, it meant that the family needed to provide direct proof of the deceased’s income, rather than relying on indirect or unsubstantiated documentation.
How does this case affect future claims for loss of earning capacity?	This case sets a precedent for requiring stringent evidence to prove loss of earning capacity, particularly for individuals with higher incomes. It emphasizes the need for direct testimony and reliable documentation to support such claims in Philippine courts.
What was the interest rate imposed on the monetary awards?	An interest rate of 6% per annum was imposed on the amounts awarded, computed from the time of finality of the decision until full payment. This is a standard practice to compensate for the delay in receiving the compensation.

In summary, the Supreme Court’s decision underscores the critical importance of presenting admissible, non-hearsay evidence when claiming damages for loss of earning capacity. By setting aside the CA’s award based on unsubstantiated cash vouchers, the Court reaffirmed the principle that claims for financial loss must be supported by reliable and verifiable proof. This ruling serves as a reminder to legal practitioners and claimants alike to meticulously gather and present competent evidence to ensure fair and just outcomes in tort cases.

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, PETITIONERS, VS. CELERINA R. ANGELES, EDWARD ANGELO R. ANGELES AND CELINE ANGELI R. ANGELES, RESPONDENTS., G.R. No. 187899, October 23, 2013