Tuesday, January 22, 2019

Case Digest: Purugganan vs. Paredes G.R. No. L-23818 I January 21, 1976


FACTS:
Plaintiff-appellee Emilio Purugganan is the owner of a piece of a residential lot subdivided as Lot 1 and Lot 2, adjacent to and bounded on the North by the lot of defendant-appellant Felisa Paredes. The lots of Purugganan are subject to an easement of drainage in favor of Paredes fully quoted in the Decree of Registration.

In or about the month of March 1951, the defendants-appellants constructed a house on their lot adjacent to Lots 1 and 2 of plaintiff-appellee in such a manner that the southern side of their house is exactly on the brick wall, the southern side of which is the demarcation line between the plaintiff-appellee and the defendants-appellants, demolishing said brick wall and built thereon the southern wall of their house with 3 windows. The house constructed by the defendants-appellants is 2-½ meters longer than the length of roofing allowed in the abovequoted Decree of Registration, and has an outer roofing (eaves) of 1.20 meters, protruding over the property of the plaintiff-appellee which is .20 meters wider than that allowed in the same Decree of Registration, and the rain water from the GI roofing falls about 3 meters inside Lots 1 and 2 of the plaintiff-appellee. The defendants-appellants also placed 3 windows each on the first and second floors of their house on the side facing Lots 1 and 2 of plaintiff-appellee. From the time the defendants-appellants started to construct their house, the plaintiff-appellee has repeatedly and continuously been demanding from the defendants-appellants that the construction of their house be in accordance with the easement, but the defendants-appellants refused to observe the easement and to close their windows. They also prohibited the plaintiff-appellee from constructing a party wall between points 1 and 2 of Lot 2 and between points 2 and 3 and 4 of Lot 1.

ISSUE:
(1) Whether or not an easement of drainage exist in favour of plaintiff-appellee; and (2) Whether or not defendants-appellants had acquired easement of light and view by prescription through user since time immemorial.

DECISION:
The plaintiff-appellee is entitled to an easement of drainage as annotated on the Certificate of Title. Thus defendant-appellant should reconstruct its roofs and eaves of their house such that the falling water shall not fall on curve into the lots of the plaintiff beyond one meter from the boundary line and by 8-½ meters in length and to remove the said protruding eaves and roof.

No easement of light and view was acquired by defendant-appellants by prescription. Indeed if defendants-appellants had acquired the said easement of light and view by prescription through user since time immemorial why did they not intervene in the registration proceedings for the inclusion of said easement in the Certificate of Title of plaintiff-appellee as an encumbrance thereon, in the same manner that the easement of drainage was annotated in the Certificate of Title of plaintiff-appellee? The easement of drainage was inscribed in the Certificate of Title of plaintiff-appellee in their favor by virtue of an amicable settlement resulting from their opposition to the registration of plaintiff-appellee's property. In this light, their defense of user "since time immemorial" becomes flimsy and is merely being used to simulate a factual issue.

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