G.R. No. L-906, July 29, 1911
MARIA CUYUGAN, plaintiff, vs. EUSEBIO AGUAS, and now his heirs, and TELESFORO QUINTANA, defendants

FACTS

In a prior case, the estate of the deceased Anastacio Aguas, which was in the possession of Maria Cuyugan, was sequestered and placed under the administration of trustees Eusebio Aguas and Telesforo Quintana. The appellate court later declared the sequestration null and void and ordered the property returned to Cuyugan. The trustees then rendered accounts of their administration. Cuyugan objected to these accounts and filed a complaint seeking their correction, payment of the balance in her favor, and indemnity for damages from alleged bad administration. The trial court ruled in favor of Cuyugan, ordering the trustees to correct the accounts and pay her the balance and damages. Eusebio Aguas appealed. During the appeal, critical records, including the accounts, tenant notebooks, and other documents necessary for review, were lost and could not be found despite court orders. The appellant’s heirs moved for a new trial due to the impossibility of obtaining a complete record for appellate review.

ISSUE

Whether a new trial should be granted when essential trial records are lost without the fault of the appellant, making it impossible for the appellate court to review the evidence upon which the judgment was based.

RULING

Yes. The Supreme Court set aside the appealed judgment and ordered a new trial. The Court held that where, through no fault or neglect of the defeated party, the trial record is lost or incomplete, depriving that party of the right to a proper appeal, a new trial is warranted. The impossibility of replacing the lost records (including the accounts and related documents) prevented the Court from reviewing all the evidence considered by the trial court. Therefore, the heirs of Cuyugan were granted the right to renew their claim or file a new amended complaint, and the lower court was directed to conduct a new trial in accordance with the Code of Civil Procedure, allowing both parties to use existing documents and evidence. No costs were awarded.