Case Digest (G.R. No. 207146) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Larry and Rosarita Williams v. Rainero A. Zerda, G.R. No. 207146, decided on March 15, 2017, the respondent Rainero A. Zerda owned Lot No. 1177-B (the dominant estate) in Barangay Lipata, Surigao City, covered by TCT No. T-18074, which lacked access to a public highway. Behind it lay a mangrove swamp owned by the Republic, to the sides were lots owned by Woodridge Properties, Inc. and Luis G. Dilag, and in front was Lot No. 1201-A, owned by petitioners Spouses Larry and Rosarita Williams, along which the national highway ran. On July 28, 2004, Zerda filed a complaint for easement of right of way against the Spouses, alleging lack of adequate outlet, refusal to grant a right of way despite his offer to pay indemnity or swap land, and selection of a path least prejudicial to the servient estate. The Williamses countered that Zerda had purchased with notice of isolation, intervened in their negotiations with a prior owner in bad faith, and that the requested route was ne Case Digest (G.R. No. 207146) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Respondent Rainero A. Zerda owned Lot No. 1177-B (dominant estate), 16,160 sq m, TCT No. T-18074, Barangay Lipata, Surigao City.
- Petitioners Spouses Larry and Rosarita Williams owned Lot No. 1201-A (servient estate) fronting the national highway; adjacent lots included Lot No. 1177-C (Woodridge Properties, Inc.), Lot No. 1206 (Luis G. Dilag), and Lot No. 7298 (Republic of the Philippines).
- Trial Court Proceedings
- July 28, 2004: Zerda filed for an easement of right of way, alleging his lot had no adequate highway access and that he had formally requested a right of way (Jan. 27, 2004) with offer to pay or swap land, which Spouses Williams refused.
- Spouses Williams moved to dismiss, contending (a) Zerda’s isolation resulted from his own purchase with notice of enclosure, (b) he intervened in their prior negotiations with the former owner, and (c) the claimed route was not the shortest and would cause prejudice; they counterclaimed for moral and exemplary damages.
- Lower Court and CA Rulings
- RTC (Sept. 11, 2006): Dismissed Zerda’s complaint, awarded Spouses Williams ₱30,000 moral and ₱20,000 exemplary damages; later reduced (Feb. 8, 2007) by deleting moral damages.
- CA (Nov. 28, 2012): Reversed RTC, held isolation was not self-caused, Zerda acted in good faith, and his proposed route was least prejudicial and shortest; remanded to determine indemnity. Motion for reconsideration denied (Apr. 16, 2013).
Issues:
- Whether Zerda is entitled to an easement of right of way under Articles 649 and 650 of the Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)