Case Summary (G.R. No. L-4555)
Case Background
The case stems from a wrongful death action where Patricio Surro was convicted of homicide through reckless imprudence for causing the death of Hermenegildo L. Co. Plaintiff's heirs reserved the right to file a separate civil action for damages, following the conviction. The Court of First Instance of Manila awarded the plaintiffs indemnity totaling P25,155 for loss of earnings, moral damages, and pecuniary expenses while deferring the liability of the Manila Electric Company until after Patricio Surro's execution of judgment was unsatisfied.
Award of Damages
The indemnity amount awarded comprises P18,000 for the deceased's salary over four years (1946 to 1949), P5,000 for moral damages, and P2,155 for actual expenses. The lower court based its decision on various factors including the tender ages of the heirs, the deceased’s life expectancy, health condition, earning capacity, pain and suffering, and the financial situation of the defendants. However, not all potential factors were fully applied; only a few were emphasized.
Legal Basis
Philippine law on civil liability arising from crimes is governed by the Revised Penal Code, specifically Articles 104 and 107, which address restitution and consequential damages. Besides, Commonwealth Act No. 284 establishes the minimum civil liability for wrongful death. The court highlighted that this legal framework supports determining indemnity based on the average earnings and the deceased's familial impact.
Calculation of Lost Earnings
The court found that the deceased was earning a salary of P250 per month and had his salary increased to P750 by the end of 1948. The total indemnity for lost earnings was thus computed reasonably, covering four years, despite the lower court limiting its analysis to this shorter period. The court emphasized that life expectancy, health, habits, and social conditions are critical in assessing the approximate earnings over a longer term, which provides a broader understanding of the deceased’s potential income.
Evaluation of Health and Life Expectancy
The deceased's health condition was deemed normal at the time of death, despite some contradictions in medical testimony regarding past health records. The court accepted the primary testimony of the family physician regarding the deceased's normal state of health and established life expectancy based on mortality tables, yet respected the discretion exercised by the lower court in limiting the indemnity's time frame.
Defense Arguments
The defendants argued that the only criterion for determining the civil liability of the Manila Electric Company should be the financial capability of Patricio Surro alone. They emphasized that Commonwealth Act No. 284 specifically focuses on this aspect. However, the court affirmed tha
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Case Overview
- This case is an appeal to the Supreme Court of the Philippines concerning the award of damages for wrongful death.
- The plaintiffs are the legitimate children and heirs of the deceased, Hermenegildo L. Co, represented by their judicial guardians, Sofronio G. Alcantara and Cornelia L. Co.
- The defendants include Patricio Surro, the chauffeur responsible for the wrongful death, and the Manila Electric Company, Surro's employer.
- The Court of First Instance of Manila awarded the plaintiffs an indemnity of P25,155, broken down into:
- P18,000 for lost salary over four years.
- P5,000 for moral and "patrimonial" damages.
- P2,155 for "pecuniary expenses," along with legal interest from the filing of the complaint.
Background Facts
- Hermenegildo L. Co died on November 24, 1945, as a result of being crushed between two trucks operated by the Manila Electric Company.
- Patricio Surro was convicted of homicide through reckless imprudence in connection with the incident.
- The plaintiffs reserved their right to pursue a separate civil action for damages during the criminal proceedings.
- The deceased was 39 years old at the time of his death, and the plaintiffs were aged 5 to 13 years.
Legal Proceedings
- Surro was convicted, and the Court of Appeals affirmed this conviction but did not mandate indemnity due to the plaintiffs' reservation of rights.
- The plaintiffs filed for damages totaling P120,177.98 aga