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JUSTICE CALLUM delivered the opinion of the court:

Plaintiff, James H. Merrill, brought this lawsuit in thecircuit court of Du Page County seeking recovery for propertydamage sustained in a motor vehicle accident with defendant, DerekHill. The matter proceeded to a jury trial resulting in a verdictof $6,750 for plaintiff. Disappointed with the amount of theaward, plaintiff filed a posttrial motion seeking, alternatively,a judgment notwithstanding the verdict, an additur, or a new trialon damages. The trial court denied the motion and plaintiffbrought this appeal. We conclude that, unless defendant consentedto an additur of $3,037.17, the trial court should have ordered anew trial on damages only.

The evidence establishes that on the evening of January 27,1997, plaintiff was driving a Volkswagen Passat west on a two-laneroad in Naperville. The accident occurred at a point where theroad curved to the south. According to plaintiff, there was alight covering of snow on the road, but he had no difficultyhandling his vehicle. Plaintiff testified that he observed avehicle operated by defendant approaching from the other direction. Defendant's vehicle did not follow the curve and crossed intoplaintiff's lane, striking plaintiff's vehicle head-on. Plaintifftestified that before the accident there was no damage to thevehicle. After the accident the whole front end had beendestroyed. Plaintiff identified a bill for $9,787.17 to repairdamage to the vehicle sustained in the accident, and he testifiedthat the bill had been paid. According to plaintiff, the vehiclewas in the repair shop for about six weeks. Plaintiff alsoidentified a paid bill for $1,010.68 for the rental of areplacement vehicle for 53 days from February 3, 1997, to March 27,1997.

Defendant called plaintiff to testify and showed him twophotographs. Plaintiff confirmed that the photographs fairly andaccurately depicted his vehicle as it appeared after the accident. Defendant made no reference to the photographs having been markedfor identification and did not ask to show them to the jury. Thephotographs were not admitted into evidence.

Defendant testified that, as he approached the curve where theaccident occurred, he observed that plaintiff's vehicle wasproceeding toward him and appeared to be "fishtailing." Defendantwas driving at about 20 miles per hour--about 5 miles per hourbelow the speed limit. Defendant applied his brakes but theylocked and the car slid. He tried pumping the brakes but could notbring the vehicle to a stop, and it collided with plaintiff'svehicle. According to defendant, the road conditions were bad. Defendant was shown the same photographs shown to plaintiff, and hetestified that they accurately represented the damage toplaintiff's vehicle. Again however, there was no reference to thephotographs having been marked for identification, defendant didnot ask to show them to the jury, and they were not admitted intoevidence.

The jury returned a verdict for plaintiff for $6,750, andjudgment was entered for that amount. Plaintiff filed a timelyposttrial motion seeking, in the alternative, a judgment of$10,797.85, notwithstanding the verdict, an additur, or a new trialon damages only. The trial court denied the motion. This appealfollowed.

We first consider whether the trial court erred in denying themotion for a judgment notwithstanding the verdict. It is firmlyestablished that "verdicts ought to be directed and judgmentsn.o.v. entered only in those cases in which all of the evidence,when viewed in its aspect most favorable to the opponent, sooverwhelmingly favors movant that no contrary verdict based on thatevidence could ever stand." Pedrick v. Peoria & Eastern R.R. Co.,37 Ill. 2d 494, 510 (1967). There is conflicting authority whetherthe trial court may direct a verdict or enter a judgmentnotwithstanding the verdict as to damages. In Chapman v. Deep RockOil Corp., 333 Ill. App. 529, 537 (1948), a judgmentnotwithstanding verdict increasing the jury's award from $2,000 to$3,100 was upheld. The plaintiff sought recovery for propertydamage that resulted from a fire caused by the defendant'snegligence. The court observed:

"Under the undisputed evidence the plaintiff, if entitled torecover at all, was entitled to recover his full damages of$3,100, which were fully covered in the pleadings. Theplaintiff testified that the value of his personal propertydestroyed by the fire was $3,100, and an itemized list ofarticles destroyed and their value was prepared by theplaintiff and it was admitted into evidence with the consentof the defendant. It was in our opinion proper for the trialcourt to mould the verdict *** to meet the evidence in thecase and to enter judgment notwithstanding the verdict for theamount which the evidence showed the plaintiff was entitled torecover." Chapman, 333 Ill. App. at 537.

In Frisch Contracting Service Corp. v. Northern Illinois Gas Co.,93 Ill. App. 3d 799, 807 (1981), this court observed that "if thedamage evidence is reasonable and undisputed *** there may beoccasions when a property damage question can be decided by thetrial judge as a matter of law." Nonetheless, we "urge[d] cautionin this respect due to the inherent and general lack ofconclusiveness of damage evidence even when no contrary evidence isoffered." Frisch, 93 Ill. App. 3d at 807; see also Baker v.Hutson, 333 Ill. App. 3d 486 (2002). In Frisch, the partiesintroduced conflicting evidence on damages and we held that adirected verdict for the defendant was therefore improper. Frisch,93 Ill. App. 3d at 807-08.

More recently, in Allstate Insurance Co. v. Mahr, 328 Ill.App. 3d 915 (2002), we held that it was error to enter a judgmentnotwithstanding the verdict in order to increase damages. In Mahr,as in the present case, the plaintiff prevailed at trial but wasdisappointed with the jury's award for damage to a motor vehicle. Though there was evidence of a paid repair bill for almost $3,000,the jury awarded only $125. The plaintiff argued that because thebill was undisputed the court should enter judgment notwithstandingthe verdict and award the full amount of the bill. The trial courtagreed. The defendant argued on appeal that the judgmentnotwithstanding the verdict was improper because evidence relatingto liability was conflicting. Mahr, 328 Ill. App. 3d at 916. Wenoted that, in reality, the judgment notwithstanding the verdictwas an additur, which was improper because the defendant did notconsent to it. We observed as follows:

"Based on the practices of the English Common law,American courts have maintained the distinction that motionsfor a directed verdict or for judgment n.o.v. are limited toliability issues. Conversely, motions for remittitur oradditur are used to contest the amount of damages. [Citations.] The trial court may grant judgment n.o.v. wherethe evidence so overwhelmingly favors the movant that nocontrary verdict based on that evidence could ever stand.[Citation.] However, additur may be awarded only where thedefendant consents to it as an alternative to a new trial,even where the damages are liquidated or the evidence ofdamages is essentially undisputed. [Citation.]

In Hughes v. Bandy, 404 Ill. 74 (1949), the supreme courtdisapproved the procedure followed here of using a motion forjudgment n.o.v. to correct an apparent error in the jury'scalculation of damages. There, the jury found for theplaintiff and awarded him $615. The trial court granted theplaintiff's motion for judgment of $1,218.25, citinguncontradicted evidence of damages in that amount. Theappellate court reversed and the supreme court affirmed theappellate court, stating, as follows:

'A disputed question of fact as to ultimate liability waspresented to the jury, and this question was decided infavor of plaintiff and against defendant. The mere factthat the evidence with respect to damages was not indispute is beside the point so far as plaintiff's motionfor judgment notwithstanding the verdict is concerned.' Hughes, 404 Ill. at 80.

The court observed that in its previous cases approvingincreases in the damage award the trial courts had done soonly with the defendants' consent as an alternative togranting new trials. Hughes, 404 Ill. at 80-81, citing Jamesv. Morey, 44 Ill. 352 (1867), and Carr v. Miner, 42 Ill. 179(1866). The court further held that, because the plaintiffhad not sought a new trial in his postjudgment motion, he wasbarred from challenging the jury's verdict. Hughes, 404 Ill.at 81." Mahr, 328 Ill. App. 3d at 916-17.

In view of the principles of Hughes and Mahr, the trial courtproperly refused to enter a judgment notwithstanding the verdict. As in Mahr and Hughes, the evidence of liability in this case wasnot so overwhelming that no verdict for defendant could ever stand. The jury found that defendant acted negligently, but it rationallycould have concluded that defendant exercised due care but wasstill unable to avoid the accident.

We next consider whether the trial court should have orderedan additur or a new trial on damages only. The two forms of reliefare related. Under the doctrine of additur, in appropriate casesthe trial court may order a new trial based on the inadequacy ofdamages unless the defendant consents to an increase in the awardof damages. See J.I. Case Co. v. McCartin-McAuliffe Plumbing &Heating, Inc., 118 Ill. 2d 447, 456-57 (1987); Carr v. Miner, 42Ill. 179 (1866). Additur is appropriate only to rectify theomission of a liquidated or easily calculated item of damages, andis improper if the defendant does not consent to it as analternative to a new trial. Hladish v. Whitman, 192 Ill. App. 3d561, 565 (1989). Because additur is essentially a conditionalruling on a motion for a new trial, the trial court should considerwhether, beyond the criteria for additur, grounds for a new trialotherwise exist.

While the amount of a verdict is generally within thediscretion of the jury, a new trial may be ordered if the damagesare manifestly inadequate or if it is clear that proved elements ofdamages have been ignored or if the amount awarded bears noreasonable relationship to the loss suffered by the plaintiff. Hollis v. R. Latoria Construction, Inc., 108 Ill. 2d 401, 407(1985). Less deference is owed to the jury's award when damages ina fixed and liquidated amount are involved, in contrast, forexample, to traditional personal injury damages. Ross v. Cortes,95 Ill. App. 3d 772, 774-75 (1981).

A new trial on damages may be ordered only where: " '(1) thejury's verdict on the question of liability is amply supported bythe evidence; (2) the questions of damages and liability are soseparate and distinct that a trial limited to the question ofdamages is not unfair to the defendant; and (3) the record suggestsneither that the jury reached a compromise verdict, nor that, insome other identifiable manner, the error which resulted in thejury's awarding inadequate damages also affected its verdict on thequestion of liability.' " Hollis, 108 Ill. 2d at 408, quotingBalestri v. Terminal Freight Cooperative Ass'n, 76 Ill. 2d 451, 456(1979).

We conclude that this case satisfies the criteria for a newtrial on damages only unless defendant consents to an additur of$3,037.17 so that the judgment would equal the amount spent torepair the vehicle. As plaintiff notes, in Ross, the courtobserved:

" 'It has been the long-followed rule in Illinois that apaid automobile repair bill is admissible in evidence withoutother foundation as prima facie evidence of the necessity andreasonableness of such repairs.' " Ross, 95 Ill. App. 3d at773, quoting Smith v. Champaign-Urbana City Lines, Inc., 116Ill. App. 2d 289, 291 (1969).

In Ross, the appellate court awarded the plaintiff an additur wherethe jury returned a verdict for $165 for property damage eventhough bills for over $3,500 to repair the damage were admittedinto evidence.

Similarly, in this case, plaintiff testified that the bill forrepairs was paid and that all the charges were related to damagesustained in the collision with defendant's vehicle. Defendantcontends that the evidence of damages was disputed. According todefendant, photographs of defendant's vehicle as it appeared afterthe accident show no damage to certain parts of the vehicle forwhich the bill shows charges for repairs. The argument isunpersuasive. While both plaintiff and defendant identifiedphotographs of plaintiff's vehicle in its postaccident condition,the photographs were never admitted into evidence. Indeed, becausethe report of proceedings does not indicate whether the photographswere marked for identification we cannot be certain that the twophotographs in the record on appeal are the ones that the partiesidentified at trial.

We agree with defendant, however, that the jury was notobliged to award plaintiff the cost of the rental of a replacementvehicle for 53 days. The jury was instructed that damages it couldaward included "[t]he reasonable rental value of similar propertyfor the time reasonably required for the repair of the propertydamaged." In his reply brief, plaintiff contends that there was noevidence that 53 days was not a reasonable amount of time spent "torepair a heavily damaged vehicle of foreign manufacture." Theimportant point, however, is that plaintiff cites no evidence that53 days was a reasonable amount of time for the repairs. Plaintiffoffered no explanation why repairing the vehicle took so long. Under the circumstances, the jury could rationally conclude, basedon ordinary experience, that 53 days was an unreasonable period oftime for the rental of a replacement vehicle.

If defendant will not consent to an additur, the applicationof the Hollis test, previously discussed, warrants a new trial ondamages only. First, the jury's verdict on liability is amplysupported by the evidence. Conflicting evidence on the issue ofliability does not necessarily preclude a new trial on damagesonly. See Vacala v. Village of La Grange Park, 260 Ill. App. 3d599, 617-18 (1994). This is so because the evidence supporting theverdict on liability need not reach the level necessary to directa verdict in order to satisfy the first part of the Hollis test. Smith v. City of Evanston, 260 Ill. App. 3d 925, 939 (1994).

Second, the issues of liability and damages are not sointertwined that a trial limited to damages would be unfair todefendant. Here the jury was not instructed on comparativenegligence. Liability and damages were separate issues.

Third, there is nothing to indicate that the jury reached averdict by compromise on the issue of liability or that the errorin the damage award also affected the verdict on liability. Acompromise verdict will not be presumed, but must appear bypositive indication of the record. Smith, 260 Ill. App. 3d at 941.

For the foregoing reasons, the order of the circuit court ofDu Page County denying plaintiff's posttrial motion is vacated, andthe cause is remanded. On remand the trial court is directed toenter an order granting plaintiff a new trial on damages onlyunless defendant consents to an additur in the amount of $3,037.17,thereby increasing the award of damages to $9,787.17.

Vacated in part; cause remanded with directions.

McLAREN and GROMETER, JJ., concur.