William Enriquez v. Isarog Line · G.R. 212008

Petitioner: William Enriquez
Respondent: Isarog Line Transport
Citation: G.R. No. 212008
Court: Supreme Court
Division: Third Division
Decided: November 16, 2016

Summary

Parents of Sonny Enriquez sued transport companies for damages after their son died in a bus collision. The main issue was whether they were entitled to P1,038,960.00 for loss of earning capacity. The RTC awarded this amount based on documentary evidence showing the deceased earned P185/day as security guard. The Court of Appeals deleted this award, ruling the certification had no probative value. The Supreme Court reversed, holding that unobjected documentary evidence is deemed admitted and sufficient to prove earning capacity. Using the established formula considering the deceased's age (26), daily wage (P185), and life expectancy, the Court reinstated the full award. This case establishes that employer certifications, when not objected to during trial, constitute competent proof for computing damages for loss of earning capacity under Article 2206 of the Civil Code.

Statutes applied

Civil Code, Art. 2206

Related cases

Other Philippine cases on the same provisions and issues.

Mariter Mendoza v. Adriano Casumpang G.R. No. 197987
Philtranco Service Enterprises v. Court of Appeals G.R. No. 120553
Caravan Travel v. Ermilinda R. Abejar G.R. No. 170631
Orlando Solis Ungsod v. People G.R. No. 158904
Suplicio Lines v. The Honorable Court of Appeals G.R. No. 113578
Philippine Airlines v. Hon. Court of Appeals G.R. No. 54470
Esther Victoria Alcala Vda. de Alcañeses v. Jose S. Alcañeses G.R. No. 187847
Dr. Eduardo Aquino v. Heirs of Raymunda Calayag; Dr. Alberto C. Reyes Vs. Heirs of Raymunda Calayag; Dr. Divinia Unite Vs. Heirs of Raymunda Calayag G.R. No. 158461

By the Intellegal Editorial Board · November 16, 2016

Search Philippine case law on Intellegal →

AI-assisted case analysis — for research only. Verify against the official decision. A research aid, not legal advice; using this page creates no attorney-client relationship. For legal advice, consult a Philippine lawyer. Verify every holding and citation against the official decision (Supreme Court E-Library / Official Gazette) before relying on it.