Saturday, May 22, 2021
Award of loss of earning capacity as a form of damages.
See - https://www.manilatimes.net/2021/01/07/legal-advice/dearpao/loss-of-earning-capacity/823912/
"x x x.
In Abrogar vs Cosmos Bottling Company and Intergames Inc. (GR 164749, March 15, 2017), ponencia of Chief Justice Lucas Bersamin, the Supreme Court held that loss of earning capacity may be awarded to the heirs of a deceased non-working victim simply because earning capacity, not necessarily actual earning, may be lost, viz:
“The RTC (Regional Trial Court) did not recognize the right of the petitioners to recover the loss of earning capacity of Rommel. It should have, for doing so would have conformed to jurisprudence whereby the Court has unhesitatingly allowed such recovery in respect of children, students and other non-working or still unemployed victims. The legal basis for doing so is Article 2206 (1) of the Civil Code, which stipulates that the defendant shall be liable for the loss of the earning capacity of the deceased, and the indemnity shall be paid to the heirs of the latter; such indemnity shall in every case be assessed and awarded by the court, unless the deceased on account of permanent physical disability not caused by the defendant, had no earning capacity at the time of his death
“Indeed, damages for loss of earning capacity may be awarded to the heirs of a deceased non-working victim simply because earning capacity, not necessarily actual earning, may be lost. xxx.” (Emphasis supplied)
In Metro Manila Transit Corp. vs Court of Appeals (GR 116617, Nov. 16, 1998, 298 SCRA 495), penned by Associate Justice Vicente Mendoza, damages for loss of earning capacity were granted to the heirs of a third-year high school student of the University of the Philippines Integrated School, who had been killed when she was hit by a passenger bus as she crossed Katipunan Avenue in Quezon City. The High Court justified the grant in this wise:
“Compensation of this nature is awarded not for loss of earnings but for loss of capacity to earn money. Evidence must be presented that the victim, if not yet employed at the time of death, was reasonably certain to complete training for a specific profession. In People v[s] Teehankee, no award of compensation for loss of earning capacity was granted to the heirs of a college freshman because there was no sufficient evidence on record to show that the victim would eventually become a professional pilot. But compensation should be allowed for loss of earning capacity resulting from the death of a minor who has not yet commenced employment or training for a specific profession if sufficient evidence is presented to establish the amount thereof.” (Emphasis supplied)
And in Pereña v[s] Zarate (GR 157917, Aug. 29, 2012),also written by Bersamin, the Court fixed damages for loss of earning capacity to be paid to the heirs of the 15-year-old high school student of Don Bosco Technical Institute killed by a moving train. The RTC and the Court of Appeals had awarded damages for loss of earning capacity computed on the basis of the minimum wage in effect at the time of his death. Upholding said findings, the Supreme Court opined:
“xxx, the fact that Aaron was then without a history of earnings should not be taken against his parents and in favor of the defendants whose negligence not only cost Aaron his life and his right to work and earn money, but also deprived his parents of their right to his presence and his services as well. xxx. Accordingly, we emphatically hold in favor of the indemnification for Aaron’s loss of earning capacity despite him having been unemployed, because compensation of this nature is awarded not for loss of time or earnings but for loss of the deceased’s power or ability to earn money.” (Emphasis supplied)
Thus, following the above-mentioned jurisprudence, you may claim the loss of earning capacity of your deceased daughter. The fact that she was still a student and unemployed should not negate her heirs’ right to claim damages in the form of loss of earning capacity precisely because compensation of this nature is awarded not for the loss of time or earnings but for the loss of the deceased’s power or ability to earn money.
For your guidance, the formula in computing the loss of earning capacity as discussed in People vs Reanzares (GR 130656, June 29, 2000), penned by Associate Justice Josue Bellosillo, is: loss of earning capacity = [2/3 x (80 – age of the deceased)] x 1/2 annual gross income.
Succinctly, the step-by-step guide to compute an award for loss of earning capacity dictates:
“(1) Subtract the age of the deceased from 80.
“(2) Multiply the answer in (1) by 2, and divide it by 3 (these operations are interchangeable).
“(3) Multiply 50 (percent) to the annual gross income of the deceased.
“(4) Multiply the answer in (2) by the answer in (3). This is the loss of earning capacity to be awarded.” (People vs Wahiman, GR 200942, June 16, 2015, Associate Justice Marvic Mario Victor Leonen’s concurring opinion).
x x x."
General Parlade has gravely undermined the Arbitral Award by calling it a “kangaroo ruling,” effectively repudiating his own Commander in Chief.
See - https://opinion.inquirer.net/139145/aid-and-comfort-to-the-enemy/amp?__twitter_impression=true
"x x x.
Aid and comfort to the enemy
By: Antonio T. Carpio
After the Philippines filed the landmark arbitration case against China on Jan. 22, 2013, China’s propagandists went overdrive on a public relations campaign, raising two issues to discredit the arbitration. First, the Philippines brought the case before the Permanent Court of Arbitration (PCA), which is not a court. Second, any arbitration case against China could not proceed without the consent of China. Both the Philippines and China have ratified the UN Convention on the Law of the Sea (Unclos) and are bound by its provisions.
The first issue — that the arbitration was filed in the wrong court—was totally laughable and was simply ignored by the Philippine legal team. Even China did not include this issue in the official Position Paper it submitted to members of the arbitral tribunal. As stated in the Philippines’ initiatory pleading called the Statement of Claim, the arbitration was filed under Article 281(1) of Unclos, which “allows recourse to the procedures provided for in Part XV, including compulsory procedures entailing binding decisions under Section 2 of Part VI.” There was no mention whatsoever of the Permanent Court of Arbitration. As every international lawyer worth his attaché case knows, the PCA is not a court but a registry that provides, for a fee, a physical venue for hearings, as well as administrative and secretarial services, to those wishing to hold their arbitrations in any of the various offices of the PCA worldwide.
The second issue — that China’s consent is needed for the arbitration to proceed — is also laughable because as every student of the Law of the Sea knows, Unclos provides for a compulsory arbitration. Every state that ratified Unclos gave its consent in advance, upon ratifying Unclos, to be sued under the compulsory dispute settlement mechanism of Unclos. This is embodied in the Unclos arbitration provision which states, “Absence of a party or failure of a party to defend its case shall not constitute a bar to the proceedings.”
Last March 28, 2021, Lt. Gen. Antonio Parlade Jr., an incumbent officer of the Armed Forces of the Philippines known for red-tagging journalists, wrote in an online publication an opinion piece that repeated the long discredited Chinese communist propaganda against the Arbitral Award. General Parlade wrote, “The Aquino administration took a legal strategy and brought the matter to the Permanent Court of Arbitration xxx.” Because the Permanent Court of Arbitration is not a court, General Parlade called the Arbitral Award a mere “piece of paper” that embodied a “kangaroo ruling.” Thus, General Parlade even went further than the staid “null and void” appellation that China gave to the Arbitral Award. Like the Chinese communist propagandists, General Parlade also questioned why the arbitral tribunal decided the case without the participation of China. General Parlade asked, “What loophole in heavens name could have made all these possible without China and with only the Philippines participating?”
General Parlade even questioned why the Philippines failed to secure a ruling on the territorial dispute in favor of the Philippines. General Parlade wrote, “Was the Philippines awarded any territory? Nothing.” The Philippines would have been foolish to raise a territorial issue because Unclos regulates only maritime disputes, not territorial disputes. As the Philippines clearly stated in its Statement of Claim, “The Philippines does not seek in this arbitration a determination of which Party enjoys sovereignty over the islands claimed by both of them.” Had the Philippines raised a territorial issue, its arbitration case would have been dismissed outright by the arbitral tribunal.
President Duterte, in his speech before the UN General Assembly last Sept. 22, 2020, declared: “The Award is now part of international law xxx. We firmly reject attempts to undermine it.” General Parlade has gravely undermined the Arbitral Award by calling it a “kangaroo ruling,” effectively repudiating his own Commander in Chief. Last April 4, 2021, Defense Secretary Delfin Lorenzana demanded, “China should respect Philippine xxx sovereign rights over its Exclusive Economic Zone as defined by UNCLOS and affirmed by the Arbitral Award.” General Parlade is operating outside the chain of command, repudiating his Commander in Chief and ridiculing the Defense Secretary who is the President’s alter ego.
General Parlade has clearly given “aid or comfort” to Communist China, which has occupied and continues to seize Philippine territory and maritime zones in the West Philippine Sea.
acarpio@inquirer.com.ph
x x x."
The President must come clean on the terms of his “verbal agreement” with the Chinese.
See - https://opinion.inquirer.net/139537/why-chinese-fishermen-are-in-the-wps
"x x x.
Why Chinese fishermen are in the WPS
By: Antonio T. Carpio - @inquirerdotnet
Philippine Daily Inquirer / 04:08 AM April 22, 2021
China claims that part of the West Philippine Sea (WPS) enclosed by the nine-dash line is a traditional fishing ground of Chinese fishermen. That would make about 80 percent of the Philippine exclusive economic zone (EEZ) in the WPS a traditional fishing ground of Chinese fishermen. This Chinese claim, however, has been rejected in the Award of the arbitral tribunal at The Hague. The arbitral tribunal expressly ruled that in the EEZ all historic rights, which include traditional fishing rights, have been “extinguished” upon the effectivity in 1994 of the United Nations Convention on the Law of the Sea or Unclos. China has made the same traditional fishing rights claim in the EEZs of Indonesia and Vietnam, and both countries have forcefully rejected the Chinese claim on the same ground that there are no traditional fishing rights in their EEZs under Unclos.
Traditional fishing rights, under Unclos, can exist only in “archipelagic waters” which are waters landward of the archipelagic baselines. The waters of the Philippine EEZ in the WPS are not archipelagic waters. Under customary international law, traditional fishing rights may also exist in the territorial sea. This is why the Award declared that the territorial waters of Scarborough Shoal are the traditional fishing ground of Chinese, Vietnamese, and Filipino fishermen. In the EEZ, however, there are no fishing rights by other states without the express consent of the adjacent coastal state.
There is actually a more sinister reason why Chinese fishing vessels roam en masse in the WPS. In July 2019, following the ramming in Reed Bank of the Filipino fishing vessel F/B Gem-Ver by a steel-hulled Chinese fishing vessel, President Duterte gave a justification for the presence in Reed Bank of the offending Chinese fishing vessel. President Duterte disclosed to the nation for the first time that he had a “verbal agreement” with Chinese President Xi Jinping allowing Chinese fishing vessels to fish in Philippine EEZ in the WPS. “As far as I’m concerned, I’m the owner, and I’m just giving the fishing rights. Galit sila kung bakit ko daw pinapaisda,” Mr. Duterte told Pastor Apollo Quiboloy in his TV show. Presidential legal counsel Salvador Panelo declared that the President’s verbal agreement with President Xi was “legally binding.”
Sen. Leila de Lima filed a resolution seeking a Senate investigation on the “verbal agreement” between President Duterte and President Xi. The exclusive right of Filipinos to fish in their EEZ is a sovereign right which the President cannot waive or give away unless allowed in a treaty ratified by the Senate. The public also has the right to know how many Chinese fishing vessels are allowed to fish in the WPS, considering that China has the largest fishing fleet in the world numbering at least 200,000 vessels. The public also has the right to know what months of the year the Chinese can fish, and what is the allowable fish catch in tonnage they can take from Philippine EEZ. The public must also know how long the fishing agreement will last. Unfortunately, the Senate never conducted any hearing. By neglecting to investigate the President’s “verbal agreement,” the Senate allowed the President to continue with an unconstitutional act at the expense of the Senate’s constitutional power to ratify treaties.
The strong diplomatic protests filed by Foreign Secretary Teodoro Locsin Jr., as well as the strong warnings issued by Defense Secretary Delfin Lorenzana, are not being taken seriously by the Chinese because they know they have a fishing agreement with President Duterte. The President must come clean on the terms of his “verbal agreement” with the Chinese. The Chinese, using huge steel-hulled trawlers, are taking fish from Philippine EEZ at the expense of Filipino fishermen who only use wooden fishing boats with outriggers. The Filipino fishermen are complaining of drastically declining fish catch in the WPS. The Philippines is now importing galunggong from China, the same fish that Chinese fishermen scoop in the WPS.
After President Duterte leaves office on June 30, 2022, the new administration may decide to file an arbitration case to stop China from fishing in the WPS. The Chinese may invoke their “verbal agreement” with President Duterte, and present him, together with Panelo, as their star witnesses to prove the existence of the “verbal agreement.”
acarpio@inquirer.com.ph
x x x."
Read more: https://opinion.inquirer.net/139537/why-chinese-fishermen-are-in-the-wps#ixzz6vbH59E1O
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President Duterte’s policies in the West Philippime Sea - Justice Antonio T. Carpio
See - https://opinion.inquirer.net/139964/president-dutertes-policies-in-the-wps
"x x x.
President Duterte’s policies in the WPS
By: Antonio T. Carpio - @inquirerdotnet
Philippine Daily Inquirer / 05:06 AM May 06, 2021
Presidential spokesperson Harry Roque praised President Duterte’s policies in the West Philippine Sea (WPS) as “careful, calibrated, and calculated.” In contrast, Roque assailed proposals from former foreign secretary Albert del Rosario and myself as “illegal, impractical, and irresponsible.” Let us examine President Duterte’s policies in the WPS from the lenses of the criteria specified by Roque.
First, in November 2016, a few months after the issuance of the landmark July 12, 2016 arbitral Award, President Duterte declared: “I will set aside the arbitral ruling. I will not impose anything on China.” President Duterte set aside the Award in favor of some $22-24 billion in loans and investment from China. In law, to “set aside” an award or a ruling is to abandon or reverse the award or ruling. The President has no power on his own to abandon or reverse the Award which affirmed the sovereign rights of the Philippines in its exclusive economic zone (EEZ) in the WPS. Setting aside the Award is not only illegal and unconstitutional, it also demonstrates a reckless, ill-informed and irresponsible act. To date, less than 5 percent of China’s promised loans and investments have materialized. No further loans and investments from China are expected in the remaining 13 months of the President’s term of office. President Duterte gave his full trust and confidence to President Xi Jinping whom Mr. Duterte trumpeted had promised to protect him from mutinies by the Philippine military. Obviously, the wily President Xi hoodwinked Mr. Duterte.
Second, in September 2016, President Duterte announced that the Philippine Navy shall patrol only the territorial sea of the Philippines facing the WPS and shall not patrol Philippine EEZ in the WPS. President Duterte stated: “[T]he territory is limited to the 12-mile limit. Hanggang diyan lang tayo.” This is clearly an illegal directive, being in patent violation of the Constitution which commands that the “State shall protect the nation’s marine wealth in its xxx exclusive economic zone.” Unless the Philippine Navy and Coast Guard patrol our EEZ in the WPS, we cannot stop Chinese ships from conducting seismic surveys for oil and gas in our EEZ in the WPS. We cannot also stop Chinese fishermen from poaching in our EEZ in the WPS. This directive of President Duterte is not only unconstitutional, it is also ill-conceived and irresponsible.
Third, President Duterte announced in July 2019 that he had entered into a verbal fishing agreement with President Xi allowing Chinese fishermen to fish in Philippine EEZ in the WPS. This verbal fishing agreement is illegal, being in clear violation of the Constitution which commands that the State “shall reserve the use and enjoyment” of the marine wealth in Philippine EEZ “exclusively to Filipino citizens.” Filipinos fish in the WPS with small wooden boats fitted with outriggers, while the Chinese, who have the largest fishing fleet in the world, fish with huge modern trawlers. We now import galunggong from China, the same galunggong Chinese fishermen take in the WPS. This verbal fishing agreement is not only unconstitutional, it is also plain dumb.
Fourth, President Duterte has announced repeatedly that “China is in possession of the WPS.” The President made this announcement on the following occasions: the November 2018 Asean-India Summit in Singapore, his July 2019 and 2020 State of the Nation Addresses, and most recently in a late night TV address last April 19, 2021. This is, of course, grossly factually incorrect, because China is actually in possession of only eight geologic features in the Spratlys plus Scarborough Shoal. The territorial seas of these geologic features—where territorial seas are applicable—constitute less than 7 percent of the total maritime area of the WPS. The freedom of navigation operations of the US and its allies in the WPS forcefully demonstrate that China is not in possession of the WPS. To concede that China is in possession of the WPS is not only grossly irresponsible, it is also clearly illegal because it is in derogation of our sovereign rights in the WPS.
Finally, President Duterte announced in his July 2019 State of the Nation Address that he is “inutile” when it comes to defending the WPS. In law, this statement is res ipsa loquitur — the statement speaks for itself: a betrayal of national interest.
x x x."
Read more: https://opinion.inquirer.net/139964/president-dutertes-policies-in-the-wps#ixzz6vbFB6vX8
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Foreign judgments - SyCip Salazar Hernandez & Gatmaitan - Christopher A Capulong, Ramon I Rocha IV and Ricardo Ma. P.G. Ongkiko
"x x x.
Examination of the foreign judgment
Vitiation by fraud
Will the court examine the foreign judgment for allegations of fraud upon the defendant or the court?
When raised as an issue, Philippine courts will examine the foreign judgment for allegations of fraud since the foreign judgment may be repelled by evidence of fraud (section 48, Rule 39 of the Rules of Court). Whether or not there was fraud will be decided by the court where enforcement of the foreign judgment is sought on the basis of its own internal law (Coquia and Aguiling-Pangalangan, Conflict of Laws: Cases, Material and Comments, p556 (2000)).
To hinder the enforcement within this jurisdiction of a foreign judgment, fraud must be extrinsic – that is, fraud based on facts not controverted or resolved in the case where judgment is rendered, or which would go to the jurisdiction of the court or would deprive the party against which judgment is rendered a chance to defend the action to which it has a meritorious case or defence. In contrast, intrinsic fraud – that is, fraud that goes to the very existence of the cause of action, such as fraud in obtaining the consent to a contract – is deemed already adjudged, and it therefore cannot militate against recognition or enforcement of the foreign judgment (PAWI v FASGI Enterprises Inc, 342 SCRA 722, 737 (2000)). Although there appears to be no specific ruling by the Supreme Court on the matter, Philippine courts may look into the defence of collusion, which is akin to fraud, under the express provisions of section 48, Rule 39 of the Rules of Court.
Public policy
Will the court examine the foreign judgment for consistency with the enforcing jurisdiction’s public policy and substantive laws?
The court cannot give effect to a foreign judgment that contravenes the Philippines’ laws, customs and public morals (Arca v Javier, 95 Phil 579 (1954)). To extend the effect of a foreign judgment in the Philippines, Philippine courts must determine whether the foreign judgment is consistent with domestic public policy and other mandatory laws (Fujiki v Marinay, 700 SCRA 69, 91 (2013)). Prohibitive laws concerning persons, their acts or property, and those that have for their object public order, public policy and good customs, shall not be rendered ineffective by laws or judgments promulgated, or by determinations or conventions agreed upon, in a foreign country (article 17 of the Civil Code).
The viability of the public policy defence against the enforcement of a foreign judgment has been recognised in the Philippines. This defence allows for the application of local standards in reviewing the foreign judgment, especially when such judgment creates only a presumptive right, as it does in cases wherein the judgment is against a person. The defence is also recognised within the international sphere, as many civil law nations adhere to a broad public policy exception that may result in a denial of recognition when the foreign court, in light of the choice of law rules of the recognising court, applied the wrong law to the case. The public policy defence can safeguard against possible abuses of the easy resort to offshore litigation if it can be demonstrated that the original claim is noxious to constitutional values (Mijares v Ranada, 455 SCRA 397, 420–421 (2005)). A specific instance of public policy negating the enforcement of a foreign judgment is when an absolute divorce decree is secured by a Philippine national married to another Philippine national. According to the Philippine Supreme Court, this is contrary to the concept of public policy and morality and will not be recognised in the Philippines (Bayot v Court of Appeals, 570 SCRA 472 (2008), citing Llorente v Court of Appeals, 345 SCRA 592 (2000)).
Conflicting decisions
What will the court do if the foreign judgment sought to be enforced is in conflict with another final and conclusive judgment involving the same parties or parties in privity?
While there is no Philippine Supreme Court decision on this point, a view is taken that a conflicting decision is one of the discretionary grounds for non-recognition of foreign judgments (Coquia and Aguiling-Pangalangan, Conflict of Laws: Cases, Material and Comments, p557 (2000)).
Enforcement against third parties
Will a court apply the principles of agency or alter ego to enforce a judgment against a party other than the named judgment debtor?
Yes. In the case of a judgment or final order upon a specific thing, the foreign judgment is conclusive upon the title to the thing; hence, if the thing is held by a party other than the judgment debtor, the foreign judgment is still enforceable against the third party because it relates to the thing (section 48, Rule 39 of the Rules of Court). On the other hand, in a judgment or final order against a person, the foreign judgment is presumptive evidence of a right between the parties and their successors in interest by a subsequent title (section 48, Rule 39 of the Rules of Court), which is an express statement that the foreign judgment may be enforced against third parties provided that the third party is a successor in interest of the judgment debtor by a subsequent title. Although it appears that the Philippine Supreme Court has yet to resolve a foreign judgment case involving piercing of the corporate veil, we believe that the principles behind piercing may allow the enforcement of a foreign judgment against a party other than the judgment debtor. Examples might include where the veil of corporate fiction is being used as follows:
to defeat public convenience, as when the corporate fiction is used as a vehicle for the evasion of an existing obligation;
in fraud cases or when the corporate entity is used to justify a wrong, protect fraud or defend a crime; or
in alter ego cases, where a corporation is merely a farce since it is a mere alter ego or business conduit of a person, or where the corporation is so organised and controlled and its affairs are so conducted as to make it merely an instrumentality, agency, conduit or adjunct of another corporation (De Castro v Court of Appeals, 805 SCRA 266, 290 (2016)).
Alternative dispute resolution
What will the court do if the parties had an enforceable agreement to use alternative dispute resolution, and the defendant argues that this requirement was not followed by the party seeking to enforce?
While there appears to be no Supreme Court case that directly resolves this point, the answer here may depend on whether or not the defence that the agreement to resort to alternative dispute resolution was not followed was raised in the foreign court proceedings.
If the party raising the defence of non-compliance with the agreement to resort to alternative dispute resolution participated, but did not raise the issue, in the foreign court proceedings, we believe that the defence may be defeated under the doctrine of waiver of rights. Under Rule 4 of the Special Rules of Court on Alternative Dispute Resolution, a party to a pending action filed in violation of the arbitration agreement may request a court to refer the parties to arbitration in accordance with such agreement until the pretrial conference. After the pretrial conference, the court will only act upon the request for referral if it is made with the agreement of all the parties to the case. Applying this principle, if a party failed to invoke an agreement to resort to alternative dispute resolution in the foreign court proceedings, the Philippine courts will consider such a party to have waived the right to resort to alternative dispute resolution.
If the defence of non-compliance with the agreement to resort to alternative dispute resolution was raised in the foreign court proceedings but the foreign court ignored said defence and proceeded to hear the case and render a judgment, there may be a different approach by the Philippine courts depending on the mode of alternative dispute resolution chosen by the parties. If the mode is arbitration, we believe that the defence of non-compliance with the agreement to resort to alternative dispute resolution may be raised in light of the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958, which was ratified by the Philippine Senate; Republic Act No. 9285, or the Alternative Dispute Resolution Act of 2004; and the declared public policy of actively encouraging and promoting the use of alternative dispute resolution (section 1 of Republic Act No. 9285). On the other hand, if the mode is mediation or other similar modes, which, unlike arbitration, do not result in a binding award or decision rendered by a third party, we believe that the defence of non-compliance with the agreement to resort to alternative dispute resolution will not succeed because the nature of the mode chosen by the parties may only cause the suspension of the court proceedings (to allow the parties to go through the alternative dispute resolution process agreed upon), but may not invalidate a court judgment rendered after due proceedings.
Favourably treated jurisdictions
Are judgments from some foreign jurisdictions given greater deference than judgments from others? If so, why?
No. Foreign judgments are treated similarly regardless of the foreign jurisdiction where they may have been issued.
Alteration of awards
Will a court ever recognise only part of a judgment, or alter or limit the damage award?
The Philippine Supreme Court has yet to rule on a matter involving the recognition of only part of a judgment, or an alteration or limitation of the damage award, but we believe it is possible for the Philippine courts to recognise only part of a judgment, or alter or limit the damage award on, among other things, public policy or clear mistake of law or fact grounds (section 48, Rule 39 of the Rules of Court).
x x x."
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