Eusebio Francisco v. Intermediate Appellate Court

Summary

This Supreme Court case involved a property easement dispute between landowners Eusebio Francisco and Cresencio Ramos over compulsory right of way. Ramos' Lot 860-A became landlocked after subdivision but he had obtained adequate access through adjacent Lot 860-B via a 3-meter passageway. However, Ramos inexplicably blocked this existing route with a concrete wall then sued Francisco for easement through his property. Both lower courts granted the easement, but the Supreme Court reversed, applying the four-requisite test from Bacolod-Murcia Milling Co. The Court found Ramos failed the third requisite - that isolation must not be due to the dominant estate owner's acts. Since Ramos had voluntarily isolated his own property by blocking an existing adequate passageway, he could not claim compulsory easement through Francisco's land. The decision establishes that property owners cannot create their own isolation then demand easements through others' properties.