Ronquillo v. Roco

Summary

The Supreme Court affirmed the dismissal of plaintiffs' complaint seeking to establish an easement of right of way through prescription. Plaintiffs claimed continuous use of a passage across defendants' land for over 20 years, but defendants obstructed it by constructing a chapel and later fencing the area. The Court held that easements of right of way are discontinuous under Civil Code provisions and cannot be acquired through prescription, only by title. While a minority opinion suggested that Act No. 190 might allow prescription of discontinuous easements, the majority maintained that Civil Code provisions control. The decision clarifies that discontinuous easements, unlike continuous and apparent ones, require formal title rather than prescriptive acquisition through use.