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 Summary (G.R. No. 175510)

Purchase of Property and Deed of Absolute Sale

Petitioner-spouses Victor and Jocelyn Valdez acquired a 200 square meter portion of a 380 square meter parcel of land from respondent-spouses Francisco and Caridad Tabisula through a Deed of Absolute Sale dated January 11, 1993. The deed specifies the property’s boundaries and indicates that it is not registered under Act 496 or the Spanish Mortgage Law. The deed includes a provision stating that the Valdez spouses shall be granted a 2.5-meter wide road right-of-way on the western side of their lot, which is not included in the sale.

  • The property is classified as a residential lot.
  • The total area of the parcel is 380 square meters.
  • The sale price was P70,000.00.
  • The deed includes a warranty of ownership against claims from third parties.

Dispute Over Road Right-of-Way

Following the sale, the respondents constructed a concrete wall on the western side of the subject property. The petitioners believed this area was intended for the road right-of-way mentioned in the deed. After unsuccessful mediation attempts at the barangay level, the petitioners filed a Complaint for Specific Performance with Damages against the respondents in April 1999, over six years after the sale.

  • Petitioners sought enforcement of the road right-of-way.
  • Respondents failed to attend barangay mediation sessions.
  • The complaint was filed in the Regional Trial Court (RTC) of San Fernando City.

Respondents' Defense and Counterclaim

In their answer, the respondents contended that the easement should be taken from the western portion of the subject property, not theirs. They also claimed that the petitioners owned two adjoining properties with access to public roads, negating the need for the easement. Furthermore, they argued that a two-storey concrete house on their lot precluded the possibility of granting the easement.

  • Respondents filed a counterclaim for damages and attorney's fees.
  • They asserted that the easement could not be granted due to existing structures.
  • The respondents provided evidence of access to public roads for the petitioners.

Trial Court's Decision

The RTC dismissed the petitioners' complaint and granted the respondents' counterclaim, awarding them damages, including moral and exemplary damages, attorney's fees, and litigation expenses. The court found the petitioners' claims unmeritorious and ruled that the deed did not constitute a definite grant of the easement.

  • The trial court's decision was issued on March 18, 2005.
  • Petitioners were ordered to pay P100,000.00 in moral damages and other fees.
  • The court concluded that the deed only conveyed ownership of the property.

Court of Appeals' Ruling

On appeal, the Court of Appeals affirmed the trial court's decision, stating that the deed did not provide a clear basis for a voluntary easement. The appellate court held that the petitioners failed to demonstrate entitlement to a legal or compulsory easement under Article 649 of the Civil Code.

  • The appellate court's decision was rendered on May 29, 2006.
  • The court emphasized the lack of a definite easement grant in the deed.
  • Petitioners' motion for reconsideration was denied.

Legal Framework on Easements

An easement is defined as a real right constituted on another's property for the benefit of a different property. The Civil Code outlines the requirements for establishing easements, distinguishing between legal and voluntary easements. The petitioners sought to enforce an alleged easement based on the deed, but the court found that the stipulation was not a valid disposition of real property.

  • Article 613 defines easements as encumbrances on immovable property.
  • Article 619 distinguishes between legal and voluntary easements.
  • The deed's language indicated that the easement was not included in the sale.

Requirements for Legal Easement

To establish a legal easement of right of way, the petitioners needed to prove several conditions under Articles 649 and 650 of the Civil Code. These include the property being surrounded by other immovables, lack of adequate access to a public highway, and that the isolation was not due to the owner's actions.

  • The petitioners must demonstrate that their property is isolated.
  • Proper indemnity must be paid for the easement.
  • The right of way must be established at the least prejudicial point to the servient estate.

Petitioners' Access to Public Roads

The trial court found that the petitioners owned two adjoining properties with access to public roads, which negated their claim for an easement. The evidence indicated that the petitioners had adequate access to public highways, thus failing to meet the requirements for a legal easement.

  • Petitioners had access to two public roads.
  • The existence of these roads undermined their claim for an easement.
  • The court noted that the barangay road was not in existence at the time of the sale.

Damages Awarded to Respondents

The court found the award of moral damages to the respondents baseless, as there was insufficient evidence of moral suffering or bad faith on the part of the petitioners. The respondents' claims of sicknes...continue reading


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