G.R. No. 1385 : April 22, 1904
RAFAEL ENRIQUEZ ET AL., plaintiffs-appellees, vs. FRANCISCO ENRIQUEZ ET AL., defendants-appellants.

FACTS:
The plaintiffs, heirs of Don Antonio Enriquez, filed an action to annul a sale of real property. They alleged that the defendant, Francisco Enriquez, sold the property using a power of attorney that was a forgery, executed by Don Antonio Enriquez at a time when he was mentally and physically incapable. The property was sold to Victoriano Reyes, who then sold it to Francisco Enriquez’s wife, with no consideration paid. The alleged forgery and sale occurred approximately eighteen years before the action was filed. The defendants denied the allegations of forgery and fraud and asserted that the plaintiffs had known of the sale for over four years and had confirmed it. The trial court declared the deeds of sale null and void but did not make specific findings of fact on the critical issues of the alleged forgery of the power of attorney or the defendants’ defense of the plaintiffs’ knowledge and confirmation of the sale.

ISSUE:
Whether the trial court’s judgment is deficient and must be set aside for its failure to make written findings of fact on the material issues raised by the pleadings, as required by law.

RULING:
Yes. The Supreme Court set aside the trial court’s judgment. The Court held that, in the absence of a motion for a new trial, it could not review the evidence and was confined to deciding questions of law based on the facts found by the trial court. The trial court’s judgment was deficient because it failed to include the required written findings of fact on the pivotal issues: (1) the nullity of the power of attorney due to forgery and incapacity, and (2) the defendants’ defense that the plaintiffs had known of and confirmed the sale. Without these findings, the Supreme Court lacked a sufficient basis to render a proper decision on the legal questions presented. The case was remanded to the trial court to render a proper judgment containing the necessary findings of fact and conclusions of law on the indicated issues, without prejudice to the evidence already taken or the presentation of additional evidence. No costs were awarded.