Loss of Earning Capacity

Both the RTC and the Court of Appeals failed to consider that under Article 2206 of the Civil Code, the accused are also jointly and severally liable for the loss of the earning capacity of Biag and such indemnity should be paid to his heirs (People of the Philippines Vs. Renato Lagat y Gawan, a.k.a. Renat Gawan and James Palalay y Villarosa, G.R. No. 187044. September 14, 2011).