Helen Calimoso v. Axel D. Roullo

Summary

The Supreme Court reversed lower courts' decisions granting an easement of right-of-way through petitioners' property. While respondent's landlocked lot required access to public roads, the Court found the proposed easement failed the 'least prejudicial' requirement under Article 650 of the Civil Code. Although the route through petitioners' lot was shortest (14 meters), it would destroy existing structures including a house and wire fence. The Court emphasized that when shortest distance and least damage criteria conflict, the least prejudice standard must prevail. Alternative routes through vacant lots, though longer (43 meters), would cause no structural damage and were therefore preferable. The decision reinforces that mere convenience for the dominant estate cannot justify compulsory easement when less damaging alternatives exist, even if they require greater distance or expense.