Short answer. From the date the complaint was filed — not from the act of ingratitude, and not from the date the court decided. Article 768 of the Civil Code provides that when a donation is revoked for ingratitude, the donee shall not return the fruits except from the filing of the complaint.
What the law says
the donee shall not return the fruits except from the filing of the complaint
Civil Code, Article 768 — Return Of Fruits After Revocation. Read the full provision →
The filing-of-complaint rule
Article 768 of the Civil Code sets a specific starting date for the fruit-return obligation: when a donation is revoked for ingratitude, "the donee shall not return the fruits except from the filing of the complaint." This means the donee is entitled to keep everything the property produced before the donor filed the revocation case. Produce, rents, income, and other fruits earned before that date are the donee's to keep, regardless of how long ago the act of ingratitude occurred. The obligation to return fruits runs prospectively from the complaint, not retrospectively from the ingratitude.
The same rule applies to birth-of-child revocations and inofficious reductions
Article 768 applies the same filing-of-complaint cutoff to two other scenarios: revocations based on the causes described in Article 760 — principally the birth, survival, or adoption of a child after the donation — and reductions of inofficious donations. In all three situations, the donee keeps whatever the donated property produced before the donor or the affected heirs went to court. The policy is the same: a donee who possessed the property lawfully and in good faith should not be made to account retroactively for benefits already consumed.
The exception: condition-based revocations
Article 768 draws a sharp distinction for revocations based on the donee's failure to comply with a condition of the donation. In that case, the donee must return "not only the property but also the fruits thereof which he may have received after having failed to fulfill the condition." The reference point shifts: instead of the filing of the complaint, it is the date the condition was breached. A donee who kept receiving income from donated property while failing to honor the condition the donation imposed cannot claim the filing-of-complaint shield.
What this means for fruit accounting
If you are a donor pursuing revocation for ingratitude, the practical implication is that delay in filing comes at a cost: every month of rents, harvests, or other income the property generates before the complaint is filed stays with the donee. The obligation to account and return only begins when the case is officially initiated. Conversely, if you are a donee facing a revocation suit, any fruits you received and spent before the complaint was filed are generally not recoverable against you — though you must account for those earned from the filing date forward.