G.R. No. 1408 : January 25, 1904
MACARIO DE LEON, plaintiff-appellee, vs. ANASTASIO NAVAL, defendant-appellant.

FACTS:
Macario de Leon filed an action against Anastasio Naval to recover a sum of money allegedly owed from a loan. The trial court found as a fact that De Leon delivered 1,500 pesos to Naval as a loan and that Naval still owed 1,125 pesos. Judgment was rendered in favor of De Leon. Naval appealed, contesting the sufficiency of the evidence to prove the existence of the loan. He did not, however, file a motion for a new trial in the court below.

ISSUE:
Whether the Supreme Court can review the trial court’s findings of fact and evaluation of the evidence regarding the existence of the loan.

RULING:
No. The Supreme Court affirmed the trial court’s judgment. The Court held that, as a general rule, its jurisdiction in civil cases on appeal is limited to reviewing questions of law. The findings of fact of the trial court are final and conclusive, provided no motion for a new trial was made in the court below and the case does not fall under any of the exceptions in Section 497 of the Code of Civil Procedure (which allows for review of evidence in specific instances). Since the appellant did not move for a new trial, the Supreme Court was without authority to re-examine or weigh the evidence. The trial court’s factual finding that a loan existed and that a balance was owed was therefore binding. Based on that finding, the defendant’s obligation to pay was clear under Article 1753 of the Civil Code. The appealed judgment was found to be without error.