Artemio Santos v. The Court of Appeals

Summary

This case involves an ejectment action filed by property owner Lolita Saavedra against heirs of former lessee Fortunato Santos who continued occupying leased premises after his death without paying rentals from 1961-1989. The Metropolitan Trial Court ordered ejectment and payment of unpaid rentals. The Regional Trial Court affirmed but added reimbursement for improvements. The Court of Appeals eliminated the reimbursement award. The Supreme Court affirmed, ruling that lessees are not possessors in good faith and cannot compel reimbursement for improvements under Article 1678 of the Civil Code, which only gives lessors the option to pay. The case establishes that continued occupancy after lease expiration without payment constitutes unjust enrichment, and that awarding mandatory reimbursement for improvements was plain error correctible on appeal.