Hilario Mejica v. Alberto Yanoc

Summary

This case involves a breach of contract of carriage where passenger Alberto Yanoc was severely injured in a public utility vehicle accident operated by Hilario Mejica, resulting in leg amputation. The RTC initially awarded both moral damages and compensatory damages for loss of earning capacity. The Court of Appeals deleted moral damages for lack of bad faith and replaced compensatory damages with temperate damages due to insufficient proof of actual income. The Supreme Court affirmed the deletion of actual damages but reduced temperate damages from P1,000,000 to P500,000, applying precedents for similar disability cases. The decision establishes that temperate damages may substitute actual damages for lost earning capacity when the loss is established but the amount cannot be proven with certainty, with awards based on comparable cases and factual circumstances.