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Possessor by Tolerance - Retention and Reimbursements - admin - 03-08-2023
Art. 546, NCC
Necessary expenses shall be refunded for every possessor; but only the possessor in good faith may retain the thing until he has been reimbursed therefor.
Lessees are not builders in good faith, hence, not entitled to reimbursement for improvements.
But under 1678 of the Civil Code, if the lessees makes improvements in good faith and the lessor appropriates them upon expiration of the contract, he is entitled to payment of 1/2 of the value of the improvements.