Crispin Dichoso, Jr. v. Patrocinio L. Marcos

Summary

Petitioners filed complaint seeking easement of right of way over respondent's property, claiming they had used the passage since 1970 before it was blocked. Despite having alternative access through adjacent Spouses Arce property, petitioners sought more direct route. RTC initially granted easement finding all Civil Code requirements met. However, CA reversed, finding existing alternative route adequate despite being longer. Supreme Court affirmed CA decision, emphasizing that mere convenience insufficient for compulsory easement and that existing outlet through Arce property, though circuitous, satisfied adequacy requirement. Court stressed easements impose abnormal restrictions on servient estates requiring clear and convincing evidence of necessity, not mere convenience.