Facts:

The case involves two consolidated petitions: G.R. No. 170071 filed by the heirs of Jose Marcial K. Ochoa, namely Ruby B. Ochoa, Micaela B. Ochoa, and Jomar B. Ochoa (Petitioners), against G & S Transport Corporation (Respondent), and G.R. No. 170125 filed by G & S Transport Corporation (Petitioner) against the same heirs (Respondents). The events leading to the case began with the death of Jose Marcial K. Ochoa while he was a passenger in a taxicab owned and operated by G & S Transport Corporation. The heirs filed a Complaint for Damages against G & S with the Regional Trial Court (RTC) of Pasig City, Branch 164, claiming breach of contract of carriage. On December 27, 2001, the RTC ruled in favor of the heirs, ordering G & S to pay civil indemnity of P50,000, loss of earning capacity amounting to P6,537,244.96, attorney's fees of P100,000, and costs of litigation. The RTC later granted a Partial Motion for Reconsideration, adding P300,000 in moral da...

Facts:

Background of the Case: The case involves a Complaint for Damages filed by the heirs of Jose Marcial K. Ochoa (Ruby B. Ochoa, Micaela B. Ochoa, and Jomar B. Ochoa) against G & S Transport Corporation. The complaint arose from the death of Jose Marcial while onboard a taxicab owned and operated by G & S.

RTC Decision: The Regional Trial Court (RTC) of Pasig City, Branch 164, found G & S guilty of breach of contract of carriage and ordered it to pay the heirs:

• P50,000 as civil indemnity;
• P6,537,244.96 for loss of earning capacity of the deceased;
• P100,000.00 for attorney’s fees; and
• Costs of litigation.

Upon the heirs' Partial Motion for Reconsideration, the RTC also awarded:

• P300,000.00 as moral damages; and
• P50,000.00 as exemplary damages.

CA Decision: The Court of Appeals (CA) affirmed the RTC Decision but with modifications:

• The award for loss of income (P6,537,244.96) was deleted, as the income certificate from USAID was deemed self-serving and unsupported by competent evidence.
• Moral damages were reduced to P200,000.00, as the CA found the original award excessive.

Supreme Court Decision (March 9, 2011): The Supreme Court partly granted the heirs' petition and denied G & S's petition. The Court modified the CA Decision by:

• Ordering G & S to pay P6,611,634.59 for loss of earning capacity; and
• Reducing moral damages to P100,000.00.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Public Documents Do Not Require Authentication:

   • Under Section 19, Rule 132 of the Rules of Court, public documents, such as the USAID Certification, are admissible without further proof of their due execution or genuineness. The Certification, issued by a public officer in the performance of his official duties, is prima facie evidence of the facts stated therein.

2. Presumption of Negligence in Common Carriage:

   • Common carriers are presumed to be at fault or negligent when a passenger dies or is injured. G & S failed to present sufficient evidence to rebut this presumption, despite its claims of exercising the diligence of a good father of a family.

3. No Review of Factual Findings Without Exception:

   • The Supreme Court reiterated that it is not a trier of facts and will not review factual findings unless the case falls under one of the recognized exceptions. G & S failed to demonstrate that its case met any of these exceptions.

4. Awards Must Be Justified in the Decision:

   • Awards for attorney’s fees and costs of litigation must be supported by factual and legal justifications stated in the body of the decision. The RTC’s failure to provide such justification warranted the deletion of these awards.

Dispositive Portion:

The Supreme Court denied G & S's Motion for Reconsideration with finality. The awards for attorney’s fees and costs of litigation were deleted, while the rest of the March 9, 2011 Decision was affirmed.