Simeon Floro v. Orlando A. Llenado (Deceased)

Summary

This case involves a dispute over easement of right of way between two adjacent subdivisions. Llenado sought to establish a compulsory easement through Floro's subdivision roads after Floro barricaded the passage, claiming his subdivision had no adequate outlet to public highway. The Supreme Court ruled against Llenado, finding that no valid voluntary easement existed due to lack of agreement on terms, and that the requirements for compulsory easement under Civil Code Articles 649-650 were not met. Specifically, Llenado had an existing approved access road through the Ipapo property that he failed to develop, making the isolation his own doing. The Court emphasized that subdivision developers cannot abandon their duly approved access roads and demand easements through other properties merely for convenience, as this would defeat the protective purpose of Presidential Decree No. 957. The decision reinstated the trial court's award of damages to Floro for road damage and unauthorized use of his property.