La Vista Association v.

CA
G.R. 95252 – September 5, 1997
J. Bellosillo

Topic: Easement
Doctrine:

Petitioners: La Vista Association

Respondents: Court of Appeals et al.

Case Summary (Ito nalang basahin niyo for facts kasi di ko din gets haha):
Mangyan Road is a 15m road in Quezon City originally owned by Tuasons. Tuasons sold 1.3 sqm of their
landholdings to PBC. Paragraph 3 of the Deed of Sale provided that the boundary line between Tuason’s
property and PBC’s property would be a 15m road, divided between the two parties at 7.5m each. PBC
then sold the 1.3sqm land to Ateneo. Meanwhile, the Tuasons developed their 7.5m portion to La Vista
Subdivision. Ateneo informed La Vista that it intended to develop 16 hectares of its property along
Manyan Road into a subdivision. La Vista offered to buy the property of Ateneo which it intended to
develop with a condition that the mutual right of way between Ateneo and La Vista would be
extinguished – rejected by Ateneo. Ateneo then offered to sell the propery to the public with the condition
that the right of use of Manyan Road would be transferred to the vendee who would negotiate with the
involved parties regarding the use of the road. Solid Homes won the bidding and subsequently developed
the land into LGV! Solid Homes filed a suir against La Vista in CFI Rizal – praying that La Vista be
enjoined from preventing and obstructing the use of passage of LGV residents through Manyan road. CFI
Rizal favored Solid Homes. CA affirmed. SC affirmed as well.

Facts:
 Mangyan Road is a 15-meter wide thoroughfare in QC. Mangyan Road serves as the boundary
between La Vista on one side and Ateneo and Maryknoll (now Miriam College) on the other. 

o It is originally a part of a vast tract of land owned by the Tuasons in QC and Marikina. 

 July 1, 1949: The Tuasons sold to Philippine Building Corporation (PBC) a portion of their
landholdings by virtue of a deed of sale with mortgage.
o This amounted to Php 1.3M
o Paragraph 3 of the deed – the boundary line between the property sold and the adjoining
property owned by the Tuasons shall be a road 15 meters wide, 1/2 of which shall be taken
from the property sold and 1/2 from the portion belonging to the Tuasons. 

 December 7, 1951: PBC, then acting on behalf of Ateneo in buying the properties, sold, assigned
and formally transferred in a Deed of Assignment with Assumption of Mortgage with the consent
of the Tuasons, the subject parcel of land to Ateneo which assumed the mortgage. 

o The Tuasons developed a part of the adjoining property into a residential village known as
La Vista Subdivision.
o Thus, the boundary between La Vista and the portion sold to Phil. Building Corp. was the
15-meter wide roadway known as the Mangyan Road. 

 June 6, 1952: Ateneo sold to Maryknoll the western portion of the land adjacent to Mangyan Road.
o To which Maryknoll constructed a wall in the middle of Mangyan Road making 1/2 of it
part of its school campus.
o The Tuasons objected and later filed a complaint before the CFI of Rizal for the demolition
of the wall.
▪ Maryknoll agreed to remove the wall and restore Mangyan Road to its original
 width of 15 meters. 

 Meanwhile, the Tuasons developed its 7.5-meter share of the Mangyan Road.
o Ateneo deferred improvement on its share and erected instead an adobe wall on the entire
length of the boundary of its property parallel to Mangyan Road. 

 Jan. 30, 1976: Ateneo informed La Vista of its intention to develop some 16 hectares of its property
along Mangyan Road into a subdivision.
o In response, La Vista Pres. Manuel Gonzales clarified: Ateneo and La Vista acknowledged
the voluntary easement or a mutual right of way wherein:
▪ Ateneo’s 7 1/2 m portion was created in La Vista’s favor
▪ La Vista’s 7 1/2 m portion was created in Ateneo's favor.

 April 28, 1976: La Vista offered to buy under specified conditions the property Ateneo was
intending to develop.
o One of the conditions was that "it is the essence of the offer the mutual right of way between
ATENEO and LA VISTA Homeowners' Association will be extinguished".
o Offer NOT ACCEPTED by Ateneo.
o Ateneo offered to sell the property to the public subject to the condition that the right to
use the 15-meter Mangyan Road will be transferred to them.
▪ La Vista became one of the bidders – but lost to Solid Homes Inc.
▪ Ateneo thus executed a deed of sale in favor of Solid Homes with the condition
that the right of way will be enjoyed by Ateneo and Solid Homes.
▪ Subsequently, Solid Homes developed a subdivision now known as Loyola Grand
Villas and together they now claim to have an easement of right-of-way along
Mangyan Road through which they could have access to Katipunan Avenue.
 La Vista however informed Solid Homes that it could not recognize the right of way over Mangyan
Road because:
o (1) Phil. Building Corp and Ateneo did not comply with their obligation of providing the
Tuasons with a right of way on their 7.5 meter portion; and
o (2) Since the property was purchased for commercial purposes, Solid Homes was no longer
entitled to the right of way as Mangyan Road was established exclusively for Ateneo.
 La Vista, after prohibiting Solid Homes from traversing Mangyan Road, then constructed 1m
cylindrical concrete posts chained together at the middle of and along the entire length of Mangyan
Road
o Prevented the residents of LGV from passing through.
o Solid Homes complained to La Vista but the posts were not removed.
 To gain access to LGV through Mangyan Road, an opening through the adobe wall of Ateneo was
made and 6 cylindrical concrete posts of La Vista were destroyed.
o La Vista then stationed security guards in the area to prevent entry to LGV through
Mangyan Road. 

 Solid Homes instituted the instant case before CFI Rizal
o Prayed that La Vista be enjoined from preventing and obstructing the use and passage of
LGV residents through Mangyan Road. 

 La Vista then filed a third-party complaint against Ateneo.


Issues + Held:
1. W/N there is an easement right-of-way over Manyan Road [YES]
 From the facts, it is very apparent that the parties and their respective predecessors-in-
interest intended to establish an easement of right-of-way over Mangyan Road for their
 mutual benefit, both as dominant and servient estates.
o Proofs1 were presented that parties concerned had constituted a voluntary easement
of right of way over Manyan Road
o Like any other contract, this can be extinguished only by mutual agreement or by
renunciation of the owner of the dominant estate

 THEREFORE, the parties concerned had indeed constituted a voluntary easement of

right-of-way over Mangyan Road (extinguished only by mutual agreement)

 The predecessors in interest of both La Vista and Solid Homes, i.e., the Tuasons and the
PBC, respectively, clearly established a contractual easement of right-of-way over
Mangyan Road.
o When PBC transferred its rights and obligations to Ateneo, the Tuasons expressly
consented and agreed thereto.
o Meanwhile, the Tuasons themselves developed their property into what is now
known as La Vista.
o On the other hand, Ateneo sold the hillside portions of its property to Solid Homes,
including their right over the easement of right-of-way.

 In sum, when the easement in this case was established by contract, the parties
unequivocally made provisions for its observance by all who in the future might
succeed them in dominion.

 The argument of LA VISTA that there are other routes to LGV from Mangyan Road is
meritless.
o The opening of an adequate outlet to a highway can extinguish only legal or
compulsory easements, not voluntary easements like in the case at bar.

Ruling: The decision of the CA which affirmed the decision of the RTC are AFFIRMED.

1Proof of easement (lifted from the case)

a) the Tuasons and PBC stipulated that [the boundary road would be one 15m wide, divided equally between the 2 parties] in
their Deed of Sale

b) the Tuasons agreed and consented to the assignment of the land by PBC to Ateneo, including the obligation to contribute 7.5m
of the property to form the 15m road

c) the Tuasons filed a complaint against Maryknoll and Ateneo for breach of contract and enforcement of the reciprocal
easement on Mangyan Road, and demanded that Maryknoll remove its wall to restore the 15m road 

d) the La Vista president clarified in a letter to the Ateneo president that “Mangyan Road is a road fifteen meters wide, one-half
of which is taken from your property and the other half from the La Vista Subdivision. So that the easement of a right-of-way on
your 7 1/2 m. portion was created in our favor and likewise an easement of right-of-way was created on our 7 1/2 m. portion of
the road in your favor;”

e) in its offer to buy [the land that would later become Loyola Grand Villas], La Vista acknowledged the existence of the
contractual right of way when it expressed that the mutual right of way between Ateneo and La Vista would be extinguished if it
bought the said property and would thus become the owner of both the dominant and servient estates
f) in a letter to the Chief Justice, the La Vista president acknowledged that “one-half of the whole length of (Mangyan Road)
belongs to La Vista Assn., Inc. The other half is owned by Miriam (Maryknoll) and the Ateneo in equal portions”