Policarpio v. Salamat

Summary

This Supreme Court case resolved a dispute over fishpond usufruct rights after three of fourteen original usufructuaries died. Under Damasa Crisostomo's will, her sister Teodorica received naked ownership while fourteen children of cousins received usufruct rights. After three usufructuaries died, the naked owner's successor (Jose V. Salamat) and surviving usufructuaries both claimed the deceased's shares, causing lessees to withhold P10,714.26 in rental payments. The trial court favored the naked owner, reasoning that death extinguished the usufruct. However, the Supreme Court reversed, applying Article 611 of the Civil Code and the principle of accretion among usufructuaries. The Court held that when usufruct is constituted simultaneously in favor of several persons, it continues until the last survivor dies, with deceased usufructuaries' shares accruing to survivors. This decision established important precedent on usufructuary rights and the right of accretion in property law.