Leonila Sarmiento v. Hon. Enrique A. Agana

Summary

This case involves a property dispute where Ernesto Valentino built a house in good faith on land he believed belonged to his mother-in-law, but was actually owned by another and later sold to Leonila Sarmiento. When Sarmiento sought to eject the Valentinos, the courts applied Article 448 of the Civil Code governing builders in good faith. The Supreme Court affirmed that the landowner must choose between paying for the improvements or selling the land to the builder, and cannot refuse both options. The decision established important precedent on the rights of good faith builders and the obligations of landowners under Article 448, emphasizing that builders cannot be compelled to remove their structures when the landowner refuses to exercise either legal option available under the Civil Code.