G.R. No. 8385 - Algarra vs. Sandejas

The case involves Lucio Algarra (plaintiff and appellant) filing a civil action against Sixto Sandejas (defendant and appellee) for personal injuries sustained in an automobile collision.
The defendant’s negligence in driving the automobile was not in dispute; the central issue was the quantum of damages to be awarded.

As a result of the collision, the plaintiff sustained injuries that required a hospital stay of ten days, with the first four or five days during which he was confined to bed.
After discharge, the plaintiff underwent further treatment by a private practitioner.
The doctor’s testimony indicated that the plaintiff considered himself “well” by about the last of July, even though the plaintiff testified during trial on September 19 that he had not fully recovered.
The plaintiff claimed that due to his injuries he did no work from the accident date (July 9, 1912) up to the trial date, thereby losing income.

The plaintiff was engaged in selling distillery products on a 10 percent commission basis and earned an average of P50 per month.
Prior to the accident, he had built up a business with about twenty regular customers over a period of four years.
After the accident, he retained only four of his previous regular customers as competitors had taken over the others.
His wife made modest attempts to keep the business running, earning only about P15 during the two-month period of his incapacity.
The accident caused a significant disruption in his established business, leading to a major loss in prospective profits.

The plaintiff incurred expenses from a private practitioner, specifically paying the doctor P8 and spending an additional P2 on medicines.
The trial record indicates that these medical expenses, totaling P10 (noting that the text mentions these should be allowed, with a reference to an overall sum amounting to P110 for all expenses in context), were presented as part of the damages.

Although the lower court recognized the justness of the plaintiff’s claim for damages, it refused to award damages for the injury to his business based on established jurisprudence (citing Marcelo vs. Velasco).
The lower court’s reasoning was anchored on a quotation from Viada, suggesting that indemnity for injuries was generally confined to the period of physical incapacity.
The defendant’s liability was to repair the actual damages as provided by article 1902 of the Civil Code, which does not preclude compensatory damages beyond mere physical incapacity.
Evidence was presented as to both the loss of income for the period of enforced absence and the more nebulous loss of prospects in his established business.

Whether the plaintiff is entitled to recover damages for the loss of business profits resulting from his enforced absence due to the accident.

The issue centers on whether the loss of prospective income from an established business, which suffered significant customer attrition, constitutes recoverable damage under the applicable law.
The controversy includes whether the principle articulated in precedent cases (such as Marcelo vs. Velasco) limiting recovery to the period of physical incapacitation should preclude awarding damages for business interruption.

Whether compensatory damages should be limited exclusively to the period during which the plaintiff was physically incapacitated or extended to cover the economic impact on his business.
How to reconcile the interpretation of article 1902 of the Civil Code with principles of complete indemnity, including prospective profit losses.
Whether the loss incurred in the plaintiff's business can be ascertained with sufficient certainty to justify an award despite the difficulties inherent in quantifying future earnings.