Albar v. Carangdang

Summary

This case involved a dispute over whether a life usufruct on property rentals is extinguished when the building is destroyed by fire. The Supreme Court ruled that the usufruct continues because the will provision granting usufruct over 'rentas de las fincas' encompasses both building and land, since buildings cannot exist without land. Under Article 517 of the old Civil Code, when a building forming part of usufructed immovable property is destroyed, the usufructuary retains the right to use the land and materials. The Court emphasized that usufruct is only extinguished by total loss of the encumbered property, not partial destruction. The decision clarifies that usufructuaries have administrative rights over the property and may benefit from new constructions, while maintaining the principle that land has inherent rental value independent of structures erected upon it.