AS A RULE, DOCUMENTARY EVIDENCE SHOULD BE PRESENTED TO SUBSTANTIATE THE CLAIM FOR LOSS OF EARNING CAPACITY.

   (Philippine Hawk Corporation vs. Lee, G.R. No. 166869, February 16, 2010).  By way of exception, damages for loss of earning capacity may be awarded despite the absence of documentary evidence when: (1) the deceased is self-employed and earning less than the minimum wage under current labor laws, in which case, judicial notice may be taken of the fact that in the deceased's line of work, no documentary evidence is available; or (2) the deceased is employed as a daily wage worker earning less than the minimum wage under current labor laws. (Tan vs. OMC Carriers, Inc., G.R. No. 190521, January 12, 2011, Brion, J.).