Cresencia Cristobal v. Court of Appeals

Summary

Petitioners sought compulsory easement of right of way over respondents' property, claiming their property had no adequate access to public highway after respondents fenced their lot. The Supreme Court denied the petition, affirming lower courts' findings that an adequate alternative outlet existed through a path walk connecting to Ma. Elena Street and then to Visayas Avenue. The Court emphasized that mere convenience is insufficient for easement - there must be real necessity and absence of adequate outlet. The decision reinforced that easement requirements under Articles 649-650 of the Civil Code must be strictly proven, particularly that the dominant estate has no adequate outlet and that the proposed easement causes least prejudice to the servient estate. The Court also held that questions regarding subdivision lot conversion compliance fall under administrative agencies' primary jurisdiction, not regular courts.