Petitioner
Heirs of the Late Jaime Binuya
Respondent
Court of Appeals
Citation
G.R. No. 100493
Court
Supreme Court
Division
Third Division
Ponente
Davide, Jr., J.
Decided
July 23, 1992

Summary

This case involves an ejectment dispute between the heirs of landowner Jaime Binuya and his former lessees Carpio and Dungao. The lessees constructed/improved houses on the leased property and claimed entitlement to reimbursement as builders in good faith before eviction. The MTC ordered eviction without reimbursement, but the RTC modified this to require reimbursement first. The Supreme Court reversed, holding that lessees cannot be considered builders in good faith since they know they don't own the property and are bound by Article 1678 of the Civil Code, which gives lessors the option to pay for improvements but doesn't allow lessees to demand reimbursement. The case clarifies that the principle in Sarmiento vs. Agana doesn't apply to landlord-tenant relationships and reinforces the established doctrine that lessees cannot improve their landlords out of their property.

Statutes applied

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By the Intellegal Editorial Board · July 23, 1992

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