G.R. No. L-1294 : October 31, 1903
THE PHILIPPINE SUGAR ESTATES DEVELOPMENT COMPANY, LIMITED, plaintiff-appellant, vs. VICTORIANO DEL ROSARIO, defendant-appellee.

FACTS:
The plaintiff, Philippine Sugar Estates Development Company, Limited, filed an action to recover ₱555 as rent for the years 1897 to 1901 from the defendant, Victoriano del Rosario, for his use and cultivation of rice fields and village lots within the Hacienda of Santa Cruz de Malabon in Cavite. The plaintiff alleged that the defendant occupied the land under a lease contract originally with the Dominican Corporation, the former owner, and that the obligation to pay rent continued through subsequent transfers of ownershipfirst to Mr. Richard H. Andrews and then to the plaintiff company. The defendant generally denied the allegations. At trial, the plaintiff presented evidence attempting to prove the existence of a written lease contract, which it claimed was destroyed during the insurrection, but the trial court found that no express contract of lease was proven. The court also found no evidence as to what the lands ought to have produced or the value of their use during the period in question, especially given the wartime conditions in Cavite. The trial court dismissed the complaint. The plaintiff appealed, but did not file a motion for a new trial, limiting the appellate review to questions of law based on the findings of fact in the decision.

ISSUE:
Whether the trial court erred in dismissing the complaint and refusing to render a money judgment against the defendant for the use and cultivation of the plaintiff’s land in the absence of: (1) proof of an express contract fixing the rent, and (2) evidence of the value of the use of the land or its actual production during the period in question.

RULING:
The Supreme Court affirmed the trial court’s judgment. The Court held that, in the absence of a motion for a new trial, it could not review questions of fact or re-examine the evidence. It accepted the trial court’s factual findings that no express contract of lease was proven and that there was no evidence of the value of the use of the land or its production during the relevant years. The Court ruled that, without proof of either an express or implied contract specifying the rent, or evidence establishing the reasonable value of the use of the land, no definite sum could be awarded. A judgment for any specific amount would be speculative and unwarranted. The statement in the trial court’s decision regarding the devastation of Cavite by war was deemed superfluous and not essential to the judgment, which rested solely on the lack of proof regarding the contract and the value of the land’s use. The dismissal of the complaint was therefore proper.