People of the Philippines vs. Carlos Doctolero, Sr (G.R. No. 131866, August 20, 2001)

FACTS:

This is an appeal of the accused from the decision of the Regional Trial Court of Baguio City finding him guilty beyond reasonable doubt of the crime of murder and ordering him to indemnify the heirs of the victim the sum of P50, 000.00 as indemnity for his death; the sum of P227, 808.80 as actual damages for expenses incurred for hospitalization, doctor’s fees, funeral expenses, vigil and burial as a result of his death, and P300, 000.00 as moral damages for the pain and mental anguish suffered by the heirs by reason of his death, all indemnifications being without subsidiary imprisonment in case of insolvency, and to pay the costs.

ISSUE:

            Whether or not the trial court’s award of damages is proper.

HELD:

            The Supreme Court modified the award for damages by the trial court. It reduced the award to P112, 413.40 representing funeral expenses, which were duly proven and covered by receipts. Expenses relating to the 9th day, 40th day and 1st year anniversaries cannot be considered in the award of actual damages as these were incurred after a considerable lapse of time from the burial of the victim. With respect to the award of moral damages, the same is reduced to P50, 000.00 in accordance with existing jurisprudence.

Based on the above modifications the court ordered the accused to pay the heirs of the victim P112, 413.40 as actual damages P50, 000.00 as civil indemnity, and P50, 000.00 as moral damages plus costs.

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