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	GR Nos. 151111-12 2003-12-01	PEOPLE OF PHILIPINES v. ERNESTO M. ESCALANTE TINGA, J.
Finally, the question of damages. The award by the trial court of the amount of P50,000.00 as compensatory damages is erroneous. Actual or compensatory damages must be duly proved and established with reasonable degree of certainty, and courts cannot rely on conjecture or guesswork on the fact and extent of damages.[60]
	GR No. 113940 2000-02-15	PEOPLE v. CIELITO BULURAN Y RAMIREZ QUISUMBING, J.
As to the amount of damages, prevailing jurisprudence sets the indemnity for death in the amount of P50,000.00, which can be awarded without need of further proof other than the death of the victim.[31] The amount of P8,000.00 as actual damages should likewise be affirmed, the wife having presented a receipt (Exhibit "C") to support such claim.[32] In addition, there being one aggravating circumstance, exemplary damages in the amount of P20,000.00[33] may be awarded, pursuant to Article 2230 of the New Civil Code.