GR 2027; (September, 1905) (Digest)
March 6, 2026GR 2033; (September, 1905) (Digest)
March 6, 2026G.R. No. 2036
September 18, 1905
PARTIES:
MARIA MANONA, plaintiff-appellee,
vs.
DIONISIO OBLERO, defendant-appellant.
FACTS:
1. On March 13, 1902, Maria Manona filed an action against Dionisio Oblero before a justice of the peace in Pangasinan.
2. On March 22, 1902, the justice of the peace ruled in favor of Manona.
3. Oblero appealed to the Court of First Instance. In that court, Manona relied on her original complaint, while Oblero filed a new answer.
4. The Court of First Instance also ruled in favor of Manona. Oblero moved for a new trial, which was denied. He then appealed to the Supreme Court via bill of exceptions.
5. The bill of exceptions submitted to the Supreme Court did not include any of the evidence presented in the Court of First Instance, nor was such evidence transmitted to the Supreme Court.
ISSUE:
1. Whether the Supreme Court can review the factual findings of the lower court in the absence of the evidence presented during trial.
2. Whether the Court of First Instance erred in deciding the case based solely on the evidence presented before the justice of the peace.
RULING:
1. On the absence of evidence: The Supreme Court held that it cannot review the appellant’s claims regarding the ownership and possession of the disputed property because the evidence from the trial was not included in the bill of exceptions or forwarded to the Court. The appellee’s lack of objection to the allowance of the bill of exceptions did not constitute an agreement to omit the evidence.
2. On the alleged error of the Court of First Instance: The Supreme Court found no merit in Oblero’s claim that the Court of First Instance decided the case based only on the evidence from the justice of the peace. The judgment of the lower court explicitly stated that it was rendered after hearing witnesses from both parties and considering arguments of counsel.
DISPOSITIVE PORTION:
The judgment of the Court of First Instance was AFFIRMED. Costs were imposed on the appellant. The case was remanded to the lower court for execution of judgment after twenty days.
CONCURRING JUSTICES:
Arellano, C.J., Torres, Mapa, Johnson, and Carson, JJ., concurred.