Spouses Marcial Vargas v. Sta. Lucia Realty

Summary

Spouses Vargas owned an isolated 10,000 square-meter lot and purchased an adjacent 300 square-meter lot in Vista Real Classica subdivision specifically to obtain right of way access to Commonwealth Avenue. They sued developer Sta. Lucia Realty for compulsory easement of right of way through the subdivision's streets. The RTC granted the easement, but the Court of Appeals reversed, finding insufficient proof of legal requisites. The Supreme Court affirmed the CA, holding that the Spouses failed to prove their lot had no adequate outlet to a public highway, as they provided no evidence about the accessibility of three other adjacent lots that could potentially provide alternative access routes. The Court emphasized that compulsory easements require strict compliance with Civil Code requirements and comparative evaluation of all possible servient estates.