Case Digest (G.R. No. 204944-45) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Anastacia Quimen v. Court of Appeals and Yolanda Q. Oliveros, G.R. No. 112331 decided May 29, 1996, petitioner Anastacia Quimen and her siblings inherited and equally subdivided ancestral land in Pandi, Bulacan into contiguous lots abutting the municipal road. Anastacia’s lot was No. 1448-B-1, Sotero’s No. 1448-B-2, Rufina’s No. 1448-B-3 and Sulpicio’s No. 1448-B-4, while Antonio’s rear portion became Lot 1448-B-6-A behind Anastacia’s and 1448-B-6-B behind Sotero’s. In February 1982 respondent Yolanda Q. Oliveros purchased Lot 1448-B-6-A from Antonio through Anastacia’s administration, having been assured of a one-meter-wide right of way across Anastacia’s property at ₱200 per square meter. Respondent built a house and used that passage until Anastacia refused payment and barred access. In February 1986 Yolanda also acquired Lot 1448-B-6-B and relied on a gratis path through her parents’ land, which was obstructed by a strong-material sari-sari store. On December 29, 1987 Yol Case Digest (G.R. No. 204944-45) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Property Subdivision and Acquisition by Respondent
- Anastacia Quimen and her siblings (Sotero, Sulpicio, Antonio, Rufina) inherited a parcel in Pandi, Bulacan, and subdivided it into Lots 1448-B-1 to 1448-B-4, all abutting a municipal road; Lot 1448-B-1 belonged to Anastacia.
- Antonio’s share (Lot 1448-B-C) lay behind these lots and was divided into Lots 1448-B-6-A (behind Anastacia) and 1448-B-6-B (behind Sotero); Yolanda Oliveros bought Lot 6-A in 1982 and Lot 6-B in 1986, both lacking adequate public highway access.
- Attempted Easement and Trial Court Proceedings
- Yolanda built on Lot 6-A, used a pathway over Anastacia’s Lot 1448-B-1 under an alleged P200/sq m right-of-way promise, which Anastacia later repudiated and physically barred.
- An ocular inspection found a feasible 1 m × 5 m detour at the extreme right of Anastacia’s lot (obstructed only by an avocado tree); the trial court nonetheless dismissed Yolanda’s complaint, preferring to extend an existing path by removing part of Sotero’s store.
- Appellate Decision and Petition for Review
- The Court of Appeals reversed, granting Yolanda a right of way through Anastacia’s property as that route caused least damage and was sufficiently direct; no damages awarded due to lack of bad faith.
- Anastacia petitioned the Supreme Court, contending (a) no binding agreement existed; (b) her lot is not a servient estate; (c) the proposed route is neither shortest nor least prejudicial; and (d) any easement was extinguished by merger of ownership.
Issues:
- Whether Yolanda is entitled to an easement of right of way through Anastacia’s property either by contract or by necessity.
- Whether the 1 m × 5 m detour at the extreme right of Anastacia’s lot is the route least prejudicial to the servient estate under Article 650 of the New Civil Code.
- Whether the merger of ownership or the absence of an original contractual promise extinguished any right of way in Yolanda’s favor.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)