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PHILIPPINE AIRLINES v. CA

FACTS:

Natividad Vda. de Padilla filed a complaint against Philippine Airlines (PAL) seeking damages for the death of her son, Nicanor Padilla, who was a passenger on a PAL flight that crashed on Mt. Baco, Mindoro. Nicanor Padilla was an unmarried individual, and his mother was his sole legal heir. PAL denied any negligence and excessive damages. The parties submitted several partial stipulations of facts, which included details about Nicanor Padilla's personal and professional background, as well as information about the plane crash and the aircraft involved.

The first partial stipulation indicated that certain disputed issues regarding liability would be proven during the trial. The second partial stipulation presented information on the complete life expectancy of Filipinos, based on a book called "Filipino Experience Mortality Table," and the life expectancy tables used by various life insurance companies in the Philippines. The third partial stipulation revealed details about PAL's authorization and ratings to repair aircraft, their maintenance of aircraft for the U.S. Air Force, U.S. Navy, and commercial carriers, as well as their utilization of a Civil Aeronautics Administration (CAA) approved system of aircraft maintenance control using worksheets and work cards.

ISSUES:

  1. Whether the light inspections performed by the airline were conducted in accordance with PI-CAA regulations.

  2. Whether the maintenance records were properly kept by the Quality Control Division.

    • Whether the computation of the awarded indemnity should be based on the life expectancy of the deceased or the beneficiary.
    • Whether the evidence presented for actual damages is sufficient.

RULING:

  1. The Court did not explicitly rule on the issue of whether the light inspections were conducted in accordance with PI-CAA regulations. This issue was not discussed in the partial digest provided.

  2. The Court did not explicitly rule on the issue of whether the maintenance records were properly kept by the Quality Control Division. This issue was not discussed in the partial digest provided.

    • The awarded indemnity should be based on the life expectancy of the deceased, not the beneficiary, in accordance with Article 1764 and Article 2206(1) of the Civil Code.
    • The evidence presented for actual damages is sufficient.

PRINCIPLES:

Based on the partial digest provided, no legal principles or doctrines were discussed.

  • Damages for death caused by a breach of contract by a common carrier are computed based on the life expectancy of the deceased, not the beneficiary (Article 1764 and Article 2206(1) of the Civil Code).

  • Foreign jurisprudence is only persuasive and should be resorted to only if no local law or jurisprudence is available to settle a controversy.

  • Actual damages must be proven by clear and satisfactory evidence.

  • Competent officers of a corporation can testify on matters within their personal knowledge, such as the income and salary of a deceased officer of the same corporation.

  • Objections to the competence and admissibility of testimonies can be deemed waived if the opposing party fails to timely object or cross-examines the witnesses.

  • The best evidence rule requires the production of the original document as evidence, but it does not disqualify competent witnesses from testifying on matters within their personal knowledge.