Manuel Soriano v. Oscar Sterberg

Summary

This 1920 Supreme Court case involved a property dispute between neighbors over windows positioned too close to the property line. Plaintiff Soriano sought to compel defendant Sternberg to close windows that were only 1.36 meters from the property division line, violating Article 582 of the Civil Code which requires a 2-meter minimum distance. The defendant's house with the offending windows had been built in 1905, but Soriano only filed suit after purchasing the adjacent property in 1917. The Supreme Court reversed the lower court's order to close the windows, ruling that Soriano's cause of action had prescribed under the statute of limitations. The Court emphasized that the right of action accrued in 1905 when the violation occurred, not when Soriano acquired the property, and that thirteen years of inaction constituted laches that waived any right to relief. The decision established important precedent regarding the prescription of actions for Civil Code easement violations and the continuous operation of statutes of limitations regardless of property transfers.