Title
Spouses Custodio vs. Court of Appeals
Case
G.R. No. 116100
Decision Date
Feb 9, 1996
Petitioners fenced property, blocking access to respondents' land. Court granted right of way but denied damages, ruling no legal injury or abuse of rights.
A

Case Summary (G.R. No. 116100)

Petitioner(s) and Respondent(s)

Petitioners are owners of lots adjacent to the parcel purchased by Pacifico Mabasa. Private respondents are the owners/heirs of the parcel seeking access to the public street. The Court of Appeals and the Regional Trial Court of Pasig are the judicial respondents in the review.

Procedural History

Civil Case No. 47466 was filed on August 26, 1982 for the grant of an easement of right of way. Pacifico Mabasa died during trial and was substituted by his spouse and heirs. The RTC rendered judgment on February 27, 1990 ordering the defendants (petitioners) to give permanent ingress and egress and ordering the plaintiff to pay P8,000 as indemnity for permanent use of the passageway. The private respondents appealed; the Court of Appeals, on November 10, 1993, affirmed the RTC’s judgment but modified it by awarding actual damages of P65,000, moral damages of P30,000, and exemplary damages of P10,000. The CA denied reconsideration on July 8, 1994. Petitioners sought review by the Supreme Court.

Facts Found by the Trial Court

The court found that the Mabasa property was located behind the petitioners’ houses, with two possible passageways to P. Burgos Street: (1) a first passageway approximately one meter wide and about 20 meters from Mabasa’s residence to the street, passing between the row of houses; and (2) a second passageway about three meters wide and approximately 26 meters long but including a narrow path through a septic tank. When Mabasa purchased the lot in September 1981, tenants occupied the premises. In February 1982, upon vacancy of one tenant, petitioners’ spouses constructed an adobe fence along the first passageway and defendant Morato extended her fence so that the entire passageway became enclosed. After the fencing, the remaining tenants vacated, allegedly causing loss of rental income to Mabasa. Petitioners defended the fence construction on grounds of safety, privacy, and nuisance.

Trial Court Ruling

The RTC ordered petitioners to provide plaintiff permanent access (ingress and egress) to the public street and ordered the plaintiff to pay petitioners the sum of P8,000 as indemnity for the permanent use of the passageway. Each party was to shoulder its respective litigation expenses.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC’s grant of a right of way but modified the monetary relief by awarding the plaintiffs P65,000 as actual damages, P30,000 as moral damages, and P10,000 as exemplary damages. The remainder of the RTC decision was affirmed.

Issues Presented to the Supreme Court

Two issues were raised: (1) whether the grant of a right of way to private respondents was proper; and (2) whether the award of damages by the Court of Appeals was proper.

Waiver and Finality as to the Right of Way

The Supreme Court held that petitioners were barred from contesting the propriety of the grant of right of way because they failed to appeal from the RTC decision granting that relief. Since petitioners did not appeal, the RTC judgment became final as to them, and they could not seek affirmative relief beyond what the RTC had granted. The appellate principle invoked is that an appellee who does not appeal cannot obtain from the appellate court any affirmative relief beyond that granted by the lower court; such appellee may only defend the lower court judgment.

Legal Principles Governing Recovery of Damages

The Court reiterated the fundamental requirement that recovery of damages presupposes both (a) a legal wrong (injury, damnum et injuria) and (b) resulting damage. Mere loss or inconvenience without violation of a legal duty is damnum absque injuria and does not give rise to a cause of action. Tort damages rest on the premise of a legal injury—there must be breach of duty and imposition of liability for that breach before damages may be awarded. The Court referenced established treatises and jurisprudence to underscore that injury and damage must concur and that hardship resulting from lawful acts causing incidental damage to another generally affords no remedy.

Application of Principles to the Present Case

Applying these principles, the Supreme Court concluded that although private respondents suffered loss (unrealized rentals), there was no legal injury prior to the RTC’s grant of easement. Petitioners’ construction of a fence within their lot was a lawful exercise of ownership and not inherently contrary to morals, good customs, or public policy. Article 430 of the Civil Code allows an owner to enclose or fence his land without detriment to servitudes constituted thereon; and Article 21’s doctrine on abuse of rights requires that acts be willful and contrary to morals, good customs or public p

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.