Case Summary (G.R. No. L-5724)
Procedural History
– March 28, 2006: Filing of complaint for compulsory easement before RTC.
– February 2007: Ocular inspection of properties.
– April 11, 2007: RTC dismisses complaint for failure to prove least prejudicial route and existence of adequate outlet.
– August 12, 2010: CA affirms RTC decision.
– October 28, 2010: CA denies motion for reconsideration.
– December 22, 2010: Petition for review under Rule 45 filed with the Supreme Court.
Factual Background
– Petitioner’s lot is entirely surrounded by other estates and has no direct access to public roads.
– Respondents’ 1,500-sqm parcel encircles petitioner’s lot; a 113-sqm portion was identified by petitioner as the least prejudicial easement strip.
– An irrigation canal separates petitioner’s property from an alternate public road; petitioner’s neighbors built bridges to cross it.
– Petitioner traces isolation to her mother’s brother (Dominador Ramos), who allegedly mis-conveyed access rights. Respondents attribute isolation to petitioner’s predecessor’s subdivision.
Applicable Law
– 1987 Constitution (property rights protection).
– Civil Code, Arts. 649–650 on compulsory easement of right of way:
• Dominant estate must be surrounded, without adequate outlet, and isolation not self-caused.
• Easement must follow route least prejudicial to servient estate; indemnity required.
Issue on Appeal
Whether petitioner is entitled to a compulsory easement of right of way over respondents’ property.
Analysis of Compulsory Easement Requisites
- Dominant estate surrounded and without adequate outlet.
- Isolation not due to acts of dominant-estate owner.
- Proposed easement is at the point least prejudicial to servient estate.
- Payment of proper indemnity.
Adequate Outlet
– Ocular Inspection Report confirms an existing public road fronting petitioner’s property across a four-meter irrigation canal.
– Petitioner may construct a bridge, as nearby landowners did, subject to National Irrigation Administration conditions.
– Jurisprudence holds that mere inconvenience does not justify imposition of easement if an outlet exists.
Least Prejudice to Servient Estate
– Proposed 113-sqm route would destroy respondents’ garage, garden, and grotto.
– Civil Code requires selection of route causing least damage, even if longer.
– Alternate bridge route over irrigation canal entails less structural prejudice to respondent
Case Syllabus (G.R. No. L-5724)
Facts of the Case
- Petitioner Alicia B. Reyes is the registered owner of a 450-sqm parcel (Lot No. 3-B-12, TCT No. T-343642-(M)) in Barangay Malibong Bata, Pandi, Bulacan.
- Respondents Spouses Francisco S. Valentin and Anatalia Ramos own a contiguous 1,500-sqm tract that completely surrounds petitioner’s lot.
- Petitioner alleges her lot became isolated when her predecessor-in-interest (her uncle Dominador Ramos) wrongfully conveyed the entire 1,500 sqm instead of the intended 500 sqm, closing the only access to the barangay road.
- The only practicable right-of-way sought is a 113 sqm portion of respondents’ property nearest the highway and allegedly least prejudicial to respondents.
- Petitioner insists no outlet existed except through respondents’ land; respondents point to an alternate public road accessed by crossing a four-meter irrigation canal, where concrete bridges already exist.
Procedural History
- March 28, 2006: Complaint for compulsory easement of right of way filed in RTC, Malolos, Bulacan.
- February 2007: Ocular inspection conducted at agreed location, confirming both the canal and an alternate barangay road.
- April 11, 2007: RTC Decision denied the complaint, holding the proposed easement was not the least prejudicial route and noting an existing canal crossed by bridges.
- April 2007: Petitioner appealed to the Court of Appeals (CA).
- August 12, 2010: CA Decision affirmed the RTC in toto, finding no reversible error and ruling petitioner failed to prove the statutory requisites for compulsory easement.
- October 28, 2010: CA denied petitioner’s motion for reconsideration.
- December 22, 2010: Petit