G.R. No. 165952 - Aneco Realty and Development Corp. vs. Landex Development Corp.

Fernandez Hermanos Development, Inc. (FHDI) originally owned a tract of land in San Francisco Del Monte, Quezon City.
FHDI subdivided the land into 39 lots and sold 22 lots to petitioner Aneco Realty and Development Corporation (Aneco); the remaining 17 lots were sold to respondent Landex Development Corporation (Landex).

The conflict arose when Landex began constructing a concrete wall on one of its lots.
Aneco filed a complaint for injunction to restrain Landex from completing the wall and later supplemented the complaint seeking demolition of the wall and damages amounting to ₱2 million.
Landex argued it did not deprive Aneco of access to its lots, citing alternative entrances on Miller Street, Resthaven Street, and San Francisco del Monte Street—though one access was blocked by Aneco’s own building.
Landex further claimed that the lots sold to Aneco were ordinary lots, not subdivision lots, per the deed of sale indicating FHDI was no longer pursuing subdivision.

The RTC initially ruled in favor of Aneco, ordering Landex to stop or remove the wall, pay ₱50,000 actual and compensatory damages, ₱20,000 attorney’s fees, and costs.
Landex filed a motion for reconsideration without including a notice of hearing, a procedural defect later remedied by a motion to set the hearing.
Aneco filed a motion for execution, asserting the RTC decision was final due to the defect in the motion for reconsideration.
Aneco failed to attend the motion for reconsideration hearing but was given additional time to comment, which it did.
The RTC eventually granted Landex’s motion for reconsideration and dismissed Aneco’s complaint, finding the case was not applicable under subdivision road closure laws as the property never existed as a subdivision. The court also found Aneco had access to public roads and that Landex had not been indemnified for use of its property.

Aneco appealed to the CA, but the latter affirmed the RTC’s dismissal of the injunction complaint.
The CA held that Aneco knew at sale that the lots were not subdivision lots based on the express stipulation in the deed of sale.
Citing Article 624 of the Civil Code, the CA found that any prior easement for road use ceased upon the sale indicating lack of subdivision intent.
The CA held Aneco failed to prove requisites for compulsory easement rights:

The dominant estate being surrounded and without adequate public highway access.
Proper indemnity paid.
Isolation not caused by Aneco’s own acts.
Right of way claimed being least prejudicial to servient estate.

Aneco filed a petition for review on certiorari to the Supreme Court under Rule 45.
Aneco raised procedural and substantive grounds to reverse the CA ruling.

Whether the RTC and CA committed reversible error by liberally applying the rule on notice of hearing under Section 5, Rule 15 of the 1997 Rules of Civil Procedure despite Landex’s defective motion for reconsideration initially lacking a notice of hearing.

Whether Aneco has a clear legal and enforceable right to enjoin Landex from constructing a concrete wall on its own property, particularly in the context of alleged easement rights, subdivision status, and ownership rights.