GR L 62988; (February, 1985) (Digest)
G.R. No. L-62988 February 28, 1985
FELINA RODRIGUEZ-LUNA, JOSE R. LUNA and ROBERTO R. LUNA, JR., petitioners, vs. THE HON. INTERMEDIATE APPELLATE COURT, JOSE E. DELA ROSA and LUIS DELA ROSA, respondents.
FACTS
Petitioners, the heirs of Roberto R. Luna, filed a suit for damages after his death in a vehicular collision on January 18, 1970, at a go-kart practice area in Greenhills, San Juan. The collision involved a go-kart driven by the deceased and a Toyota car driven by then 13-year-old Luis dela Rosa, who was unlicensed. The Court of First Instance of Manila awarded damages totaling over P1.7 million, including P1.65 million for unearned net earnings. The Intermediate Appellate Court initially affirmed this decision but, upon reconsideration, reduced the award for unearned net earnings to P450,000. The private respondents’ separate petition for review was dismissed. This case is the petitioners’ appeal, seeking reinstatement of the original P1.65 million award and interest on the attorney’s fees.
ISSUE
The primary issues are: (1) whether the Court of Appeals erred in reducing the award for unearned net earnings from P1.65 million to P450,000; and (2) whether the award for attorney’s fees should earn legal interest.
RULING
The Supreme Court ruled in favor of the petitioners. On the first issue, the Court found the appellate court’s modification unjustified. The trial court’s computation of P1.65 million was based on a life expectancy of 30 years and an annual net income of P55,000 (gross of P75,000 less personal expenses of P20,000). The appellate court, without sufficient basis, reduced the life expectancy to 15 years and increased the annual personal expenses, thereby lowering the net income. The Supreme Court held that the trial court’s findings, affirmed in the appellate court’s original decision, were supported by evidence, including expert testimony on life expectancy and documentation of the deceased’s income. The appellate court’s subsequent reduction constituted a reversible error, as it altered factual findings already affirmed and made inconsistent adjustments to income and expenses without evidence.
On the second issue, the Court granted legal interest on the award for attorney’s fees. While the trial and appellate court decisions did not originally provide for such interest, the Court, exercising discretion under Article 2211 of the Civil Code, ruled that the attorney’s fees, awarded as damages in this quasi-delict case, should earn legal interest from the date of the trial court’s decision (July 5, 1973) to serve the ends of justice. The Court rejected the private respondents’ plea for equity to make the father’s liability merely subsidiary, noting that the son, now of age, is abroad with no reachable assets, making strict application of the law necessary. The appellate court’s resolution was set aside, and its original decision reinstated with the modification on interest.