Spouses Cesar v. Court of Appeals

Summary

The Fajardo spouses sought to establish a compulsory easement of right of way through the Sta. Maria family's properties to access the provincial road from their landlocked 1,043 sq.m. property in Obando, Bulacan. The trial court granted the easement after finding all legal requisites satisfied, ordering a 75 sq.m. right-of-way with P3,750 indemnification. The Court of Appeals affirmed but increased the valuation to P2,000 per square meter. The Supreme Court affirmed in toto, holding that the Sta. Maria properties provided the shortest and least prejudicial route compared to alternative routes through neighboring Cruz or Jacinto properties. The Court applied Civil Code Articles 649-651, emphasizing that easements must be established where the twin elements of shortest distance and least damage concur, and rejecting arguments that the isolation was self-induced or that adequate alternatives existed.