Sps. Tedy Garcia v. Loreta T. Santos

Summary

The Supreme Court established that when two properties were formerly owned by one person and one property contains apparent signs of easement (such as windows and openings) that continue to exist after the property is sold to another person, Article 624 of the Civil Code creates an easement of light and view by title without need for formal prohibition. The Court reversed lower courts that had dismissed the complaint, finding that Sps. Garcia acquired such easement when they purchased their property from Sps. Santos in 1998, since the windows and openings in their house constituted apparent signs of easement that continued after the sale. The Court ordered respondents to remove portions of their building to comply with the three-meter distance rule under Article 673 of the Civil Code, as their structure was built only two meters from the boundary line.