Well, I have a hard time imagining a real damage you could suffer that wouldn't involve damaging, moving, or rearranging the property. But I don't think I can object to this argument unless you're going to say that loss of potential revenue counts as a "real damage".
Requiring certainty is kind of absurd. Even if I blow up your car, it could have blown up by itself a few minutes later.
One school of thought is that you have to prove the loss was more likely than not, and if so, you're entitled to the entire amount. (The 51% rule.) This seems pretty unreasonable to me.
Yet another is that you're entitled to the expected lost value. So if I deprive you of a 35% chance to make $15,000, your recovery is $5,250, the fair market value of a 35% chance of making $15,000.
Another is that you're never entitled to recovery for low probability losses, but you're entitled for the full recovery once a loss is at least somewhat probable. This means that if you have a lottery ticket whose numbers you haven't recorded, no recovery is possible if I rip it up, even though you just paid $1 for that ticket.
My own sense is that the "fair market value" of the loss comes the closest to what is actually fair. So if I can prove that you deprived me of a 1% chance at $1,000,000, I'm entitled to a $10,000 recovery.