Adriana Dionisio v. Rodolfo Ortiz of the Regional Trial Court of Quezon City

Summary

Property owners disputed easement rights over Howmart Road after respondents opened a new gate following lot subdivision. Petitioners erected a barricade blocking the gate, prompting respondents to seek injunctive relief. The RTC granted preliminary mandatory injunction ordering barricade removal. The Supreme Court reversed, holding that respondents had no clear right to the easement since the QCIEA agreement expired in 1988 and continued use was merely by tolerance without valid renegotiation. The Court applied Article 649 of the Civil Code, which prohibits compulsory easement when property isolation results from the owner's own acts, specifically the wall construction between subdivided lots. The decision emphasized that preliminary injunction requires clear and unmistakable rights, which respondents failed to establish.