Liwayway Andres v. Sta. Lucia Realty & Development

Summary

Petitioners sought easement of right-of-way through respondent's subdivision to access public road, claiming ownership of surrounded agricultural land through 50-year adverse possession. The RTC initially granted the easement based on extraordinary prescription under Article 1137 of the Civil Code. However, the Court of Appeals reversed, finding insufficient proof of ownership and possession. The Supreme Court affirmed the dismissal, ruling that unregistered public agricultural land cannot be acquired through prescription without express State declaration converting it from public domain to patrimonial property. The case establishes that only persons with real rights over property may demand easements, and that prescription of public lands requires prior governmental conversion to private ownership. This decision clarifies the limitations on acquiring public domain lands through adverse possession.