Philippine Airlines v. Hon. Court of Appeals

Summary

This case arose from PAL Flight 26's crash on Mt. Baco, Mindoro in 1960, killing passenger Nicanor Padilla. His mother sued for damages, with the central issue being whether death indemnity should be computed based on the deceased's life expectancy or the surviving beneficiary's life expectancy. The Supreme Court definitively held that under Articles 1764 and 2206(1) of the Civil Code, damages for death must be calculated using the deceased's life expectancy, not the beneficiary's. The Court corrected the trial court's mathematical error, reducing the award from P477,000 to P417,000, representing the deceased's net annual income of P13,900 multiplied by his 30-year life expectancy. Due to the 16-year litigation delay, the Court added 6% annual interest from the original judgment date, recognizing how inflation had eroded the award's value while the deceased's mother had died awaiting resolution.