G.R. No. 175510 - Spouses Valdez vs. Spouses Tabisula

Petitioners: Spouses Victor and Jocelyn Valdez, represented by their Attorney-in-Fact, Virgilio Valdez.
Respondents: Spouses Francisco Tabisula and Caridad Tabisula.
Subject Property: A 200 square meter portion of a 380 square meter parcel of residential land in San Fernando, La Union. The entire 380 sq.m. parcel was described as bounded on the North by Lot No. 25569; East, by Lots No. 247 and 251; South, by a creek; West, by Lot No. 223-A. The parcel was assessed at ₱17,100 and was not registered under Act 496 or Spanish Mortgage Law.

On January 11, 1993, the respondents sold to petitioners the eastern 200 sq.m. portion of the 380 sq.m. parcel through a Deed of Absolute Sale for ₱70,000.
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.”
Respondents warranted to defend the ownership of the 200 sq.m. property against any claims.

Respondents later constructed a concrete wall on the western side of the subject property.
Petitioners, assuming the wall blocked the promised road right-of-way, sought mediation at the barangay level. Respondents failed to attend mediation conferences.
Petitioners filed a Complaint for Specific Performance with Damages in April 1999 before the Regional Trial Court (RTC), requesting respondents to provide the 2 1/2-meter easement and remove the wall.

Respondents argued the easement should be within the western part of the subject property, not on their lot.
They claimed petitioners and their family owned adjoining properties with access to two public roads—Burgos Street and a barangay road—thus negating the need for an easement on respondents’ property.
They contended a two-storey concrete house exists on the disputed easement area on their lot, built prior to the sale, making an easement there impossible.
They supported their claims with a letter from the City Engineer’s Office dated February 20, 2003.

The RTC dismissed petitioners’ complaint and granted respondents’ counterclaim, awarding ₱100,000 moral damages, ₱50,000 exemplary damages, ₱50,000 attorney’s fees, ₱30,000 litigation expenses, and costs against petitioners.
Petitioners appealed to the Court of Appeals (CA), which affirmed the RTC decision in a May 29, 2006 decision, holding that:

The deed conveyed ownership only to petitioners and did not grant a definite easement;
Petitioners failed to prove entitlement to a legal or compulsory easement under Article 649 of the Civil Code.

The CA denied petitioners’ motion for reconsideration.
Petitioners filed a petition for review on certiorari before the Supreme Court, challenging:

Whether the 1993 Deed of Absolute Sale granted petitioners a valid and enforceable road right-of-way easement on the western side of the subject property.
Whether petitioners are entitled to a legal or compulsory easement of right of way under Article 649 of the Civil Code due to lack of access to a public road.
Whether the award of moral and exemplary damages and attorney’s fees to respondents was proper.
Whether respondents were precluded from filing a counterclaim due to non-appearance in barangay mediation.