Facts:

The case involves the petitioners, Spouses Victor Valdez and Jocelyn Valdez, represented by their attorney-in-fact, Virgilio Valdez, against the respondents, Spouses Francisco Tabisula and Caridad Tabisula. The events leading to the case began with a Deed of Absolute Sale executed on January 11, 1993, wherein the petitioners purchased a 200 square meter portion of a 380 square meter parcel of land located in San Fernando, La Union from the respondents. The deed specified that the property was classified as a residential lot and included a provision for a 2.5-meter wide road right-of-way on the western side of the lot, which was not included in the sale.

After the sale, the respondents constructed a concrete wall on the western side of the subject property, which the petitioners believed obstructed the intended road right-of-way. Following unsuccessful mediation attempts at the barangay level, the petitioners filed a Complaint for Specific Performance with Damages against t...

Facts:

1. Purchase of Property: Petitioners, Spouses Victor and Jocelyn Valdez, purchased a 200 sq.m. portion of a 380 sq.m. parcel of land from respondents, Spouses Francisco and Caridad Tabisula, through a Deed of Absolute Sale dated January 11, 1993.
2. Road Right of Way: The deed included a provision stating that petitioners "shall be provided a 2 1/2 meters wide road right-of-way on the western side of their lot but which is not included in this sale."
3. Construction of Wall: Respondents later built a concrete wall on the western side of the subject property, which petitioners believed was the intended road right of way.
4. Barangay Mediation: Petitioners reported the matter to the barangay for mediation, but respondents failed to attend the scheduled conferences.
5. Filing of Complaint: Petitioners filed a Complaint for Specific Performance with Damages in April 1999, seeking to enforce the provision of the road right of way and to remove the concrete wall.
6. Respondents' Defense: Respondents argued that the easement should be taken from the western portion of the subject property, not their lot. They also claimed that petitioners had access to two public roads through adjoining properties.
7. Trial Court Decision: The Regional Trial Court (RTC) dismissed the complaint and awarded damages to respondents.
8. Court of Appeals Decision: The Court of Appeals affirmed the RTC decision, ruling that the deed did not grant a definite easement and that petitioners were not entitled to a legal easement of right of way.

Issue:

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Ruling:

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Ratio:

1. Voluntary Easement: A voluntary easement must be clearly established in a written agreement and recorded in the Registry of Property to be enforceable. The provision in the deed was vague and did not constitute a definite grant of an easement.
2. Legal Easement Requirements: To establish a legal easement of right of way under Article 649 of the Civil Code, the dominant estate must be isolated and lack adequate access to a public highway. Petitioners failed to meet these requirements.
3. Damages: Moral and exemplary damages require proof of bad faith or ill-motive, which was absent in this case. Respondents' counterclaim was also barred under the Local Government Code for their failure to appear before the barangay lupon.