G.R. No. 185240 - Salimbangon vs. Tan

Guillermo Ceniza died intestate on July 11, 1951, leaving a parcel of land in Poblacion, Mandaue City.
On July 17, 1973, his children Benedicta, Guillermo, Jr., Victoria, Eduardo, and Carlos executed an extrajudicial declaration of heirs and partition, dividing the land among themselves into five lots (A, B, C, D, E), each with specific easements of right of way:

Lot A (Benedicta) subject to a 1.5-meter wide road right of way along its NW boundary for Lots B, E, and D.
Lot B (Eduardo) subject to a 1.5-meter wide road right of way along its SW boundary for Lots A, D, and E.
Lot C (Carlos) with no easement restrictions.
Lot D (Guillermo, Jr.) subject to a 1.5-meter wide road right of way along its NE boundary for Lots B and E.
Lot E (Victoria) subject to a 1.5-meter wide road right of way along its SW boundary for Lot D.

Lots A, B, and C were adjacent to a city street, whereas Lots D and E were interior lots without direct street access. To provide access, the heirs created a 3-meter wide alley easement right of way involving portions of Lots A and B.

Later, the heirs modified the agreement by eliminating the easements along Lots A, D, and E.
They instead imposed a 3-meter wide alley easement exclusively along the southwest boundary of Lot B, running from Lots D and E to the street.
The modification intended to address concerns about the fairness of the partition and the small size of some lots.

Victoria swapped her Lot E with Benedicta’s Lot A, becoming owner of Lot A, which is adjacent to the city street.
The Salimbangons (Victoria and spouse) constructed a residence on Lot A and built two garages; one garage accessed the street directly, while the other used the easement alley on Lot B, which they cemented and gated.

Respondents Santos and Erlinda Tan purchased Lots B, C, D, and E, constructing improvements on Lot B that infringed on the easement area and closed the Salimbangons’ gate to the alley.
The Salimbangons filed a complaint with the city engineer regarding this obstruction.
The Tans initiated a case (Civil Case MAN-3223) in the Regional Trial Court (RTC) seeking extinguishment of the easement and damages, and applying for preliminary injunction.
RTC upheld the Salimbangons’ easement right but denied damages. Both parties appealed.
The Court of Appeals (CA) reversed the decision, extinguished the easement on Lot B due to consolidation of ownership of Lots B, D, and E, and denied damages.
The CA admitted testimony from Eduardo Ceniza, one of the original heirs, that the easement was intended solely for the benefit of interior Lots D and E, not Lot A.
The Salimbangons moved for reconsideration, which the CA denied, prompting the current petition.

Whether the Court of Appeals erred in admitting extrinsic evidence (testimony of Eduardo Ceniza) that allegedly modifies or contradicts the terms of the written partition agreement, in violation of the parol evidence rule.

Whether the Court of Appeals erred in ruling that the easement of right of way established by the partition agreement in favor of Lot A has been extinguished upon consolidation of ownership of Lots B, D, and E.