Title
Spouses Valdez vs. Spouses Tabisula
Case
G.R. No. 175510
Decision Date
Jul 28, 2008
Spouses Valdez sought to enforce a 2.5m road right-of-way from Spouses Tabisula per a 1993 deed. Courts ruled the provision was vague, no legal easement existed, and reversed damages awarded to respondents.
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Case Digest (G.R. No. 175510)

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:

  1. Whether the provision in the Deed of Absolute Sale granting a 2 1/2-meter road right of way is enforceable.
  2. Whether petitioners are entitled to a legal or compulsory easement of right of way under Article 649 of the Civil Code.
  3. Whether the award of moral and exemplary damages to respondents is justified.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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