Waterworks v. Court of Appeals · G.R. L-54526

Petitioner: Waterworks
Respondent: Court of Appeals
Citation: G.R. No. L-54526
Court: Supreme Court
Division: Second Division
Ponente: Feria, J.
Decided: August 25, 1986

Summary

MWSS (successor to NAWASA) sought to remove useful improvements worth P255,000.00 from Dagupan Waterworks System after City of Dagupan was declared lawful owner. The Supreme Court unanimously held that possessors in bad faith have no right to reimbursement or removal of useful improvements. Under Civil Code Articles 449, 546-547, only good faith possessors may seek indemnity or remove improvements. Bad faith possessors lose all improvements without compensation. The Court rejected MWSS's procedural argument that the removal issue was impliedly consented to, noting no evidence was presented on removability. This decision reinforces the Civil Code's strict treatment of bad faith possessors and clarifies that equitable considerations cannot override clear statutory provisions protecting property owners from bad faith builders.

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Reyes v. Sta. Maria G.R. No. L-33213
Heirs of Torres v. Goduco-Mendoza G.R. No. 233370
Roxas v. Valencia G.R. No. L-3826
Teodoro v. Balatbat G.R. No. L-6314
Recoletos v. Crisostomo G.R. No. 10031
Labajo v. Enriquez G.R. No. L-11093
Rodriguez v. Francisco G.R. No. L-13343
Lopez v. Gloria G.R. No. 13846

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By the Intellegal Editorial Board · August 25, 1986

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