St. Michael School of Cavite v. Masaito Development Corporation

Summary

St. Michael School sought to establish an easement of right-of-way through Citihomes subdivision for access to public highway under Article 649 of the Civil Code. The school's only access was through a 61-square meter lot owned by respondent corporations who demanded excessive payment. Lower courts dismissed the case for procedural defects and lack of cause of action. The Supreme Court reversed, holding that petitioners substantially complied with verification requirements and that the complaint sufficiently alleged the three elements required under Article 649: (1) dominant estate surrounded by other properties without adequate outlet, (2) willingness to pay proper indemnity, and (3) isolation not due to proprietor's acts. The Court emphasized that annexes showing the location plan and photographs must be read together with the complaint's allegations to determine sufficiency of cause of action. The case establishes important precedent on procedural compliance and substantive requirements for easement cases.