Programme Incorporated v. Province of Bataan

Summary

Programme Incorporated challenged Province of Bataan's ownership of Piazza Hotel, claiming rights as lessee. The hotel was originally owned by BASECO and leased to Programme Incorporated in 1986. After PCGG sequestered BASECO's assets in 1989, the property was sold to Province of Bataan for tax delinquency. The Supreme Court affirmed lower courts' findings that Province of Bataan validly acquired ownership through the tax sale, evidenced by its certificate of title and tax declaration. Programme Incorporated, as mere lessee, had no ownership rights and could not claim benefits under Civil Code Article 448 for possessors in good faith, as such provisions do not apply to lessee-lessor relationships. The Court emphasized that lessees cannot improve landlords out of their property and found no evidence that Programme Incorporated constructed the hotel at its own expense.