Primary Holding

A summary judgment was correctly rendered because the defendants-appellants violated the conditions of a registered easement of drainage and failed to demonstrate a genuine issue of material fact that would necessitate a full trial. Furthermore, any prescriptive easement of light and view was extinguished by the registration of the servient estate under the Torrens System without such easement being annotated.

Background

Plaintiff Purugganan owned lots burdened by a registered easement of drainage in favor of Defendant Paredes' adjacent property. Paredes constructed a house that exceeded the easement's specifications, causing rainwater to improperly drain onto Purugganan's property. Purugganan sued to enforce the easement, while Paredes claimed her house was pre-existing and not in violation.

Facts

• 1. Purugganan owned Lots 1 and 2, subject to a registered easement of drainage for Paredes’ benefit.
• 2. The easement originated from an "Amicable Settlement" during land registration, allowing Paredes to drain rainwater onto Purugganan's property within specified dimensions (8-1/2 meters length, 1 meter width).
• 3. Paredes built a house with a roof and eaves exceeding the easement’s dimensions, causing rainwater to fall excessively onto Purugganan's land.
• 4. Paredes also installed windows facing Purugganan's property, claiming a pre-existing easement of light and view.
• 5. Purugganan repeatedly demanded compliance with the easement, but Paredes refused.
• 6. A court-appointed commissioner's report confirmed the house's roof and eaves violated the easement's dimensions.

Arguments of the Petitioners

• 1. Defendants-appellants violated the registered easement of drainage by constructing a house with roofing exceeding the allowed dimensions.
• 2. No genuine issue of material fact existed, justifying summary judgment.
• 3. Defendants-appellants’ claims of pre-existing house and prescriptive easement of light and view are invalid against the registered easement and Torrens title.

Arguments of the Respondents

• 1. Genuine issues of material fact exist, making summary judgment improper.
• 2. The house was reconstructed on the ruins of a pre-existing house built before the easement registration, thus not violating it.
• 3. The brick wall is exclusively owned by them.
• 4. They have acquired an easement of light and view by prescription due to the windows existing for a long time.
• 5. The lower court erred in concluding a violation of the easement without considering the commissioner's report in its totality.

Issues

• 1. Did the lower court err in rendering a summary judgment?
• 2. Did the defendants-appellants violate the registered easement of drainage?
• 3. Did the defendants-appellants acquire an easement of light and view by prescription?

Ruling

• 1. The Supreme Court affirmed the summary judgment.
• 2. The court found no genuine issue of material fact because the commissioner's report, to which the defendants-appellants agreed, confirmed the violation of the easement's dimensions.
• 3. The court clarified that the easement's dimensions referred to the area where rainwater could fall on the servient estate, not the physical dimensions of the roof itself.
• 4. The court ruled that any easement of light and view acquired by prescription was extinguished upon the registration of Purugganan's land under the Torrens system, as such easement was not annotated on the title.

Doctrines

• 1. Summary Judgment: A procedural device to promptly dispose of cases where there is no genuine issue of material fact.
• 2. Easement of Drainage: A servitude where one estate (dominant) has the right to drain water onto another estate (servient).
• 3. Torrens System and Indefeasibility of Title: A system of land registration where a registered title is generally conclusive and indefeasible, except for encumbrances noted on the certificate.
• 4. Extinguishment of Unregistered Easements: Unregistered easements on a servient estate are extinguished upon its registration under the Torrens System if not annotated on the title.

Key Excerpts

• 1. "Translated, it means the easement of receiving water falling from the roof which is an encumbrance imposed on the land of the plaintiff-appellee. Consequently, the distances prescribed in the Decree of Registration should not correspond to the width and length of the roof of the defendants-appellants' house but to the distance of the rain water falling inside the land of the plaintiff-appellee because the encumbrance is not the roof itself but the rain water falling inside the property of the plaintiff-appellee."
• 2. "Granting that in the instant case an easement of light and view was acquired by prescription, it was cut off or extinguished by the registration of the servient estate under the Torrens System without the easement being annotated on the corresponding certificate of title, pursuant to Sec. 39 of the Land Registration Act (Act 496)."

Precedents Cited

• 1. Cid vs. Javier, 108 Phil. 850, 853: Used to support the doctrine that an easement of light and view, even if acquired by prescription, is extinguished if not annotated on the Torrens title of the servient estate.

Statutory and Constitutional Provisions

• 1. Article 675 of the New Civil Code: Referred to concerning constructions not violating the easement of drainage. (Note: While mentioned in the dispositive portion of the lower court summary judgment, it's not discussed in detail by the Supreme Court’s decision itself in the provided text, but it is indirectly relevant to the concept of easement of drainage.)
• 2. Section 39 of Act 496 (Land Registration Act): Cited as the basis for extinguishing unannotated easements upon registration of the servient estate under the Torrens System.
• 3. Section 3 of Rule 34 of the Rules of Court: Cited regarding the propriety of summary judgment.