G.R. No. 258841 - Juan Ponce Enrile vs. Sandiganbayan and People

Over 50 years before the case, Maria Florentino owned two properties in Vigan, Ilocos Sur: a house with four windows on its north side (three on the upper story and one on the ground floor) and a camarin (warehouse) adjacent to the house.
Through a will dated September 6, 1885, Maria Florentino devised the house and its lot to Gabriel Florentino and Jose Florentino (respondents), and the camarin and its lot to Maria Encarnacion Florentino.
Maria Florentino died (disputed date: 1885 or 1892). At the time of her death, no mention was made or action taken by the devisees regarding the windows. The respondents continued to enjoy light and air through these windows.

On July 14, 1911, Maria Encarnacion Florentino sold the camarin lot, where the warehouse stood, to petitioner, Severo Amor. The deed stated Maria Encarnacion inherited the property from her aunt, Maria Florentino.
In January 1938, Severo Amor demolished the old warehouse and began building a two-story house on the lot.
The respondents filed an action on March 1, 1938, to prohibit Amor from constructing a building that would obstruct the light and air through their windows.
The Court of First Instance denied the preliminary injunction on March 15, 1938, since the new building was nearly completed.

The Court of First Instance declared an easement of light and view in favor of the respondents' property and ordered the petitioner to remove obstructions and refrain from constructing within three meters from the boundary line, awarding P200 in damages.
The Court of Appeals affirmed this judgment.
Petitioner questioned the date of Maria Florentino's death, asserting it was 1885, which would entail that the Spanish Civil Code did not govern, but instead the Law of the Partidas (pre-Civil Code Spanish law) should apply. The Court of Appeals found the death to have occurred in 1892.

Whether an easement of light and view was properly established in favor of the respondents.
Whether Article 541 of the Civil Code applies to this case, particularly regarding easements created through apparent signs between two estates formerly owned by the same person.
The proper date of Maria Florentino’s death and the governing law (Civil Code or Law of the Partidas).
Whether the petitioner is an innocent purchaser and whether he was bound to inquire about the easement.
Whether the easement was acquired by prescription.