Short answer. Yes — ten years of nonuser extinguishes an easement. For a discontinuous easement such as a right of way, the ten years run from the day it stopped being used. For a continuous one, they run from the day some act contrary to the easement took place.
What the law says
By nonuser for ten years; with respect to discontinuous easements, this period shall be computed from the day on which they ceased to be used; and, with respect to continuous easements, from the day on which an act contrary to the same took place
Civil Code, Article 631 — How Easements Are Extinguished. Read the full provision →
Ten years, counted from different days
The period is the same for every easement; the start date is not. A right of way is discontinuous — it exists only when somebody actually passes — so the clock runs from the day the passage stopped. A continuous easement operates by itself without human intervention, a drain or a light and view arrangement being the usual examples, and mere disuse tells you nothing about it. So for those the clock starts only from the day on which an act contrary to the same took place: the drain is blocked, the opening is walled up. Until something contradicts the easement, nothing is running.
The other ways an easement ends
Nonuser is one of six routes in Article 631, and a dispute often turns out to be about a different one. Merger ends the easement when one person comes to own both the dominant and the servient estate. A temporary or conditional easement ends when its term expires or its condition is fulfilled. The dominant owner may renounce it, or the two owners may agree on redemption. Before arguing about ten years of disuse, check whether one of these simpler explanations already disposed of the easement years ago.
Impossibility suspends rather than kills
The article also covers the case where the estates fall into such condition that the easement cannot be used — a collapse, a change in the ground, works that make passage physically impossible. That does not extinguish the right outright: it shall revive if the subsequent condition of the estates or either of them should again permit its use. The catch is the proviso attached to it. If, by the time use becomes possible again, sufficient time for prescription has already elapsed, the revival comes too late. Impossibility, in other words, does not stop the ten years from running in the background.
The date is the whole case
Because everything reduces to when use stopped or when the contrary act occurred, that date is what a lawyer will want evidence of first, and it is rarely in any document. It is built from dated photographs, aerial or satellite imagery, receipts for the gate or the fence that closed the passage, and the recollection of people who used the route. The certificates of title and the approved plan establish that the easement existed and where it ran; they will not tell you when anybody last walked it. Anyone who still needs the way should also be using it.