G.R. No. 95252 - La Vista Association, Inc. vs. Court of Appeals

On July 1, 1949, the Tuasons sold 1,330,556 sq.m. to Philippine Building Corporation (PBC) by Deed of Sale with Mortgage, providing that “the boundary line … shall be a road fifteen (15) meters wide, one-half of which shall be taken from the property herein sold to the Vendee and the other half from the portion adjoining belonging to the Vendors.”
On December 7, 1951, PBC, acting for Ateneo de Manila University (Ateneo), assigned and transferred the parcel to Ateneo, which assumed the mortgage and agreed to perform all terms of the 1949 deed, incorporating the 15-m road easement.
The Tuasons developed their 7.5-m share into La Vista Subdivision; Ateneo built an adobe wall along its 7.5-m share and deferred improvements.

On June 6, 1952, Ateneo sold the western portion to Maryknoll College, which erected a wall on the middle of Mangyan Road. The Tuasons sued for demolition; in amicable settlement Maryknoll restored the road to its full 15-m width.
In January and April 1976, Ateneo proposed subdivision of its adjacent land; La Vista’s president acknowledged in letters that an easement of right-of-way over each party’s 7.5-m share existed for mutual benefit. La Vista then offered to purchase Ateneo’s property on condition of extinguishing the mutual easement.
Ateneo’s May 10, 1976 offer to sell to the public, subject to transfer of right-of-way privileges, led to Solid Homes, Inc. becoming purchaser on October 29, 1976. The deed granted Solid Homes the easement privileges, with Ateneo retaining co-use and pro-rata maintenance obligations.

La Vista blocked Mangyan Road with concrete posts and security guards, denying access to Loyola Grand Villas residents (Solid Homes). Residents demolished part of Ateneo’s wall to gain entry.
On December 17, 1976, Solid Homes filed Civil Case No. Q-22450 in the CFI of Rizal for injunction against La Vista; La Vista filed third-party complaint against Ateneo.
Procedural history:

Preliminary injunction by trial court on September 14, 1983; nullified by IAC on May 31, 1985.
RTC decision on November 20, 1987, after full trial, declared an easement and granted a final injunction, ordering La Vista to desist from obstruction and to pay attorney’s fees.
CA and SC actions between 1988–1990: CA resolutions on contempt and intervention (September 21, 1989), RTC decision affirmed by CA on May 22, 1990; SC dismissed related certiorari petitions as moot or without abuse of discretion.
On June 22, 1998, the SC’s First Division in G.R. No. 95252 affirmed the CA and RTC decisions, finalizing recognition of the easement.

Whether a valid easement of right-of-way over Mangyan Road exists in favor of Solid Homes (and successors) against La Vista.
Whether prior decisions on preliminary injunctions operate as res judicata against the final injunction after trial on the merits.
Whether the availability of alternative routes negates a voluntary easement.
Whether intervention by Loyola residents during appeal was permissible.