PEOPLE VS QUILATON

GR No. L-69666 January 23, 1992

FACTS:

Herein appellant, Gumercindo Quilaton, was tried and was found guilty beyond reasonable doubt for
the crime of murder by the trial court. He was sentenced to suffer the penalty of reclusion perpetua
and to pay the offended party various amounts of money.

Particularly, the trial court rendered the following penalties:

Reclusion Perpetua
100,000 for the death of Rolando Manahan
26,445 for actual damages spent on burial and other expenses of the deceased
250,000 for moral damages

ISSUE: WON the damages awarded by the trial court were correct.
RULING:
In relation to the actual damages of P26,445.00, AFFIRMED as the brother of Rolando Manahan
testified on this matter and submitted various receipts in support of their claim for actual damages.
In relation to P100,000.00 as indemnity for the death of Rolando Manahan, REDUCED to P50,000
conformably with prevailing jurisprudence on the matter.
In relation to the award of moral damages in the amount of P250,000.00, ANALYZED, AND
CONSIDERED AS BEING LUMPED AS MORAL DAMAGES IN THIS CASE, as follows:

Aside from the ordinary indemnity for death, the appellant is obliged to pay the following, in
accordance to Art. 2206 o the New Civil Code:
a) to compensate the heirs of Rolando Manahan for the latter's loss of earning capacity

b)
c)

to give support in the form of expenses for education to the sisters of Rolando Manahan who
had been dependent on him therefor; and
to pay the heirs of Rolando Manahan moral damages for the mental anguish suffered by
them.

SC also laid down the following guidelines in determining the compensable amount of loss
earnings:
a) the number of years for which the victim would otherwise have lived

b)

the rate of loss sustained by the heirs of the deceased

- Considering that Rolando Manahan was 26 years of age at the time of death, he was
expected to live for another 46 years. This is derived by using the generally accepted formula
in computing for life expectancy, based on the 1980 CSO table.
- But a man does not normally continue working to earn money up to the final month or year
of his life; hence 46 years could be reasonably reduced to 39 years. Besides, Rolando
Manahan was a government employee who is expected to retire at the age of 65.
- If there are 261 working days in a year and Rolando Manahan was receiving P23.00 a day,
Rolando Manahan's gross earnings would be approximately P234,000.00.
- A reasonable amount must be deducted therefrom that would represent Rolando Manahan's
necessary expenses had he been living, in this case P120,000.00.
- The net or compensable earnings lost by reason of Rolando Manahan's death is, accordingly,
P114,000.00.

SC also considered and awarded P20,000.00 as morral damages o the heirs of Rolando Manahan as it


1.
2.
3.
4.
5.

was found hat their mother suffered a mild stroke upon learning of Rolando Manahan's slaying which
eventually led to her paralysis.
SC then modified the award of damages as follows:

P50,000.00 as indemnity for death;

P26,445.00 as actual damages;
P114,000.00 by way of lost earnings;
P10,000.00 by way of educational assistance to Rolando Manahan's two (2) sisters; and
P20,000.00 as moral damages.

PEOPLE VS SIA
GR NO. 137457 November 21, 2001
FACTS:

Christian Bermudez was beaten to death and the taxicab he was driving was taken by the
assailants. His lifeless body, wrapped in a carton box, was recovered several days later in a fishpond
in Meycauayan, Bulacan.

The accused in this case were tried for violation of R.A. 6539, otherwise known as the Anti-Carnapping
Law and Murder.

The trial court rendered a decision against both accused imposing upon them the supreme penalty of
Death. The accused were likewise adjudged to pay jointly and severally, the mother of the deceased
Christian Bermudez, the following:
P50,000.00 as compensatory damages for the death of Christian Bermudez

P200,000.00 as burial and other expenses incurred in connection with the death of Christian; and
P3,307,199.60 (2/3 x [80-27] x 300 per day x 26 days (excluding Sundays) x 12 months)
representing the loss of earning capacity of Christian Bermudez as taxi driver.

ISSUE: WON civil indemnity awards, as awarded by the trial court were proper.
RULING:

Anent the award of P50,000.00 for death indemnity is proper following prevailing jurisprudence. The
award of civil indemnity may be granted without any need of proof other than the death of the victim.
Without any express provision in the decision of the trial court, the SC also held that it is proper to
award P50,000.00 for moral damages taking into consideration the pain and anguish of the victims
family brought about by his death.
SC ruled the deletion of P200,000.00 for burial and other expenses incurred in connection
with the death of the victim deleted.

SC considered that there were no records of any receipt or voucher to justify the trial courts
award of burial and other expenses incurred in connection with the victims death. The rule is
that every pecuniary loss must be established by credible evidence before it may be
awarded and only those which are duly supported by receipts and other credible
evidence will only be the ones to be given credence.

SC likewise held that the trial court was correct in awarding damages for loss of earning capacity
despite the non-availability of documentary evidence. However, the amount of the trial courts award
needs to be recomputed and modified accordingly.

In determining the amount of income lost, the following must be taken into account:

the number of years for which the victim would otherwise have lived

the rate of loss sustained by the heirs of the deceased

- This is computed by multiplying the life expectancy by the net earnings of the deceased, meaning total

earnings less expenses necessary in the creation of such earnings or income less living and other incidental
expenses.
Considering that there is no proof of living expenses of the deceased, net earnings are computed
at fifty percent (50%) of the gross earnings.
In this case, the Court notes that the victim was 27 years old at the time of his death and his
mother testified that as a driver of the Tamaraw FX taxi, he was earning P650.00 a day. Hence,
the damages payable for the loss of the victims earning capacity is P2,996,867.20.
EASTERN SHIPPING LINES VS CA AND MERCANTILE INSURANCE COMPANY
GR NO. 97412 July 12, 1994
FACTS:

On December 4, 1981, two fiber drums of riboflavin were shipped from Yokohama, Japan by defendant
Eastern Shipping Lines under Bill of Lading.

Upon arrival of the shipment in Manila on December 12, 1981, it was discharged unto the custody of
defendant Metro Port Service, Inc. The latter excepted to one drum, said to be in bad order, which
damage was unknown to plaintiff.

On January 7, 1982 defendant Allied Brokerage Corporation received the shipment from defendant
Metro Port Service, Inc., one drum opened and without seal (per "Request for Bad Order Survey." Exh.
D).

On January 8 and 14, 1982, defendant Allied Brokerage Corporation made deliveries of the shipment
to the consignee's warehouse. The latter excepted to one drum which contained spillages, while the
rest of the contents was adulterated/fake (per "Bad Order Waybill" No. 10649, Exh. E).

The insurance company filed before the trial court.which rendered judgment ordering the defendants
to pay the plaintiffs, jointly and severally the following:

The amount of P19,032.95, with the present legal interest of 12% per annum from October 1,
1982, the date of filing of this complaints, until fully paid
P3,000.00 as attorney's fees and other costs.

ISSUES:
WON the applicable rate of interest, referred to above, is twelve percent (12%) or six percent
(6%)
WON the payment of legal interest on an award for loss or damage is to be computed from the
time the complaint is filed or from the date the decision appealed from is rendered;
RULING:
WON the applicable rate of interest, referred to above, is twelve percent (12%) or six percent (6%)
WON the payment of legal interest on an award for loss or damage is to be computed from the time the
complaint is filed or from the date the decision appealed from is rendered
It should be at 6% computed from the date the decision & a rate of 12% (in lieu of the 6%) shall be imposed
on such amount upon finality of this decision until the payment thereof.
SC provided rules of thumb in the application of awards of interest:

When an obligation, regardless of its source, i.e., law, contracts, quasi-contracts, delicts or quasidelicts is breached, the contravenor can be held liable for damages (governed by Title XVIII on
"Damages" of the Civil Code)

The award of interest should be further governed by the following principles:

When the obligation is breached, and it consists in the payment of a sum of money, i.e., a loan or

forbearance of money, the interest due should be that which may have been stipulated in writing.
Furthermore, the interest due shall itself earn legal interest from the time it is judicially
demanded. In the absence of stipulation, the rate of interest shall be 12% per annum to be
computed from default, i.e., from judicial or extrajudicial demand under and subject to the
provisions of Article 1169 of the Civil Code.

When an obligation, not constituting a loan or forbearance of money, is breached, an interest on

the amount of damages awarded may be imposed at the discretion of the court at the rate of
6% per annum. No interest, however, shall be adjudged on unliquidated claims or damages
except when or until the demand can be established with reasonable certainty. Accordingly,
where the demand is established with reasonable certainty, the interest shall begin to run from
the time the claim is made judicially or extrajudicially but when such certainty cannot be so
reasonably established at the time the demand is made, the interest shall begin to run only from
the date the judgment of the court is made.
When the judgment of the court awarding a sum of money becomes final and executory, the
rate of legal interest, whether the case falls under paragraph 1 or paragraph 2, above, shall be
12% per annum from such finality until its satisfaction, this interim period being
deemed to be by then an equivalent to a forbearance of credit.