Spouses Rudy Fernandez v. Spouses Merardo Delfin

Summary

This Supreme Court case involves a property dispute over easement of right of way between the Fernandez and Delfin Spouses. The Fernandez Spouses originally owned five contiguous properties, with two front properties providing access to three back properties. They annotated easements on the front properties' titles in 1980. After foreclosure, the front properties were sold to the Delfin Spouses who refused to honor the easement. The RTC ruled in favor of the Fernandez Spouses, but the Court of Appeals reversed, finding no valid easement existed. The Supreme Court reversed the CA, applying Article 624 of the Civil Code on apparent easements. The Court held that when properties previously owned by one person have apparent signs of easement, and one property is transferred, the easement continues unless specifically excluded or signs removed. This case establishes important precedent on the doctrine of apparent easements and property rights succession.