CIVIL LAW > IX. PROPERTY, OWNERSHIP, AND ITS MODIFICATIONS > B. Ownership > 8. Possession > c. Effects of Possession > iii. Right to the Fruits

I. General Concept

The right to the fruits refers to the entitlement of a possessor to the fruits (natural, industrial, or civil) produced by the thing possessed. This right is heavily governed by the distinction between the possessor in good faith and the possessor in bad faith, as established under the Civil Code of the Philippines.

II. Legal Basis

Article 441, Civil Code of the Philippines:
- “To the owner belongs the natural, industrial, and civil fruits.”
- This provision establishes the ownership of fruits as a natural incident of property ownership unless modified by possession.
Articles 443 to 445, Civil Code of the Philippines:
- These provisions address the rights of possessors, including the right to the fruits, depending on the nature of their possession.

III. Classification of Fruits

Natural Fruits:
- Products of the soil, such as crops, trees, and plants, or those produced by animals.
- Examples: rice, bananas, and the offspring of livestock.
Industrial Fruits:
- Fruits produced through cultivation or labor.
- Examples: sugarcane from a plantation or vegetables from a farm.
Civil Fruits:
- Derive from the use of a thing, such as rent, lease payments, or interest on money.
- Examples: apartment rent or bank interest.

IV. Possession and Right to the Fruits

Possessor in Good Faith:
- Defined (Art. 526): A possessor who is unaware of any flaw in their title or mode of acquisition that invalidates their possession.
- Rights to the Fruits (Art. 544):
  - A possessor in good faith is entitled to all fruits received and gathered during the period of possession.
  - They are not required to account for fruits already consumed or disposed of before a claim is made.
- Liability:
  - Obliged only to deliver or account for fruits that are still in their possession at the time good faith ceases.
Possessor in Bad Faith:
- Defined (Art. 526): A possessor aware of a defect in their title or that their possession is without legal basis.
- Rights to the Fruits (Art. 549):
  - The possessor in bad faith must reimburse the owner for all fruits gathered or received during the period of possession.
  - Liability extends to natural, industrial, and civil fruits, whether consumed or not.
- Obligations:
  - Must deliver all uncollected or extant fruits.
  - Liable for the value of lost or destroyed fruits, even if not gathered, provided the loss was due to their fault or negligence.

V. Good Faith vs. Bad Faith: Key Principles

Presumption of Good Faith:
- Possession is presumed to be in good faith unless proven otherwise (Art. 527).
Conversion of Good Faith to Bad Faith:
- Occurs upon the possessor being notified of a defect in their title or after judicial demand is made (Art. 539).

VI. Rules on Expenses for Fruits

Good Faith Possessor:
- May deduct necessary expenses incurred in producing or gathering the fruits (Art. 546).
- Entitled to reimbursement for useful improvements and necessary expenses.
Bad Faith Possessor:
- No right to reimbursement for expenses incurred.
- Liable to return or compensate the owner for the fruits and any damage caused.

VII. Applicability to Specific Cases

Usufructuaries (Art. 562):
- Entitled to enjoy the fruits of the property, provided they fulfill their obligations under the usufruct.
Builders, Planters, and Sowers (Art. 449-455):
- Rights to fruits are determined by good or bad faith and ownership of the land.
Pledges and Mortgages (Art. 2085 et seq.):
- Fruits may form part of the pledge or mortgage if expressly included.

VIII. Practical Applications

Lease Agreements:
- Lessees may gather industrial fruits but must return the property in its original state.
Property Litigation:
- Determination of good or bad faith during possession impacts claims for reimbursement of fruits or damages.
Restitution of Property:
- A bad faith possessor must account for all fruits from the time of possession, while a good faith possessor accounts only for those present when good faith ceases.

IX. Case Law Interpretations

Heirs of Ignacio Conti v. CA (G.R. No. 118464):
- Distinction between possession in good faith and bad faith clarified in relation to the fruits produced by the property.
Alano v. Planters Products, Inc. (G.R. No. L-28135):
- Affirmed liability for the value of fruits consumed by a bad faith possessor.
Edralin v. Philippine Veterans Bank (G.R. No. 177938):
- Reiterated that a good faith possessor has no obligation to reimburse the owner for fruits gathered before judicial demand.

X. Summary of Key Provisions

Possessor Type	Entitlement to Fruits	Obligations for Fruits
Good Faith	Entitled to gathered fruits	Deliver fruits in possession upon demand
Bad Faith	No entitlement to fruits	Reimburse all fruits gathered or consumed

The meticulous differentiation between good and bad faith forms the cornerstone for determining the effects of possession on the right to the fruits. Proper application of these principles ensures justice in property disputes.