Petitioner
Spouses Maximo Espinoza
Respondent
Spouses Antonio Mayandoc
Citation
G.R. No. 211170
Court
Supreme Court
Division
Second Division
Ponente
Peralta, J.
Decided
July 3, 2017

Summary

The Supreme Court affirmed that respondents who built a house on disputed land were builders in good faith, having constructed the property in 1995-1996 while believing they held valid title through deeds later declared fictitious. The Court rejected petitioners' argument that respondents were builders in bad faith, emphasizing that bad faith must be proven by clear and convincing evidence. Under Article 448 of the Civil Code, the landowner (petitioners) must choose between appropriating the building after paying indemnity or selling the land to the builders. The case was remanded to determine the fair market value of the land and proper application of the Civil Code provisions governing improvements made by possessors in good faith. The decision protects builders who act in good faith while preserving landowners' rights through the principle of accession.

Statutes applied

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By Intellegal Editorial Board · July 3, 2017

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