Sps. Manuel v. Sps. Santos

Summary

This case involves a property dispute over an easement of right of way established in a 1973 partition agreement among heirs of Guillermo Ceniza. The Supreme Court affirmed the Court of Appeals' decision extinguishing the easement when spouses Tan acquired multiple lots including both the dominant and servient estates. The Court ruled that parol evidence was admissible to show the heirs' true intent was to create the easement solely for interior lots D and E, not for street-adjacent Lot A owned by the Salimbangons. Under Civil Code Article 631(1), the easement became extinct by operation of law when ownership of the dominant and servient estates was consolidated in the same person. The decision clarifies the application of the parol evidence rule and the principle of easement extinction through consolidation of estates.