Short answer. Yes. Article 567 gives crops growing at the usufruct's end to the owner, but the owner must reimburse the usufructuary, from the proceeds of those growing fruits, the ordinary expenses of cultivation, seed, and other similar expenses the usufructuary incurred in producing them.
What the law says
the owner shall be obliged to reimburse at the termination of the usufruct, from the proceeds of the growing fruits, the ordinary expenses of cultivation, for seed, and other similar expenses incurred by the usufructuary
Civil Code, Article 567 — Growing Fruits at the Start and End. Read the full provision →
Who owns the crops at each end of the usufruct
Article 567 sets the basic ownership rule for crops still growing at the two boundary moments of a usufruct. Fruits growing at the time the usufruct begins, belong to the usufructuary, while those growing at the time the usufruct terminates, belong to the owner. So at termination, crops still in the ground or on the trees pass to the owner even though the usufructuary may have done the work and paid the costs of planting and tending them.
No refund owed at the start, but reimbursement owed at the end
The article treats the two transitions asymmetrically. At the beginning, the usufructuary... has no obligation to refund to the owner any expenses incurred — he simply receives the benefit of crops the owner may have already invested in. At termination, though, the balance tips the other way: because the owner is the one who benefits from crops the usufructuary planted and cultivated, the owner shall be obliged to reimburse the usufructuary for the ordinary expenses of cultivation, for seed, and other similar expenses.
Reimbursement comes from the proceeds of the crops themselves
The article specifies the source of this reimbursement: it is paid from the proceeds of the growing fruits — meaning the value of the crops the owner is receiving is what funds the payback to the usufructuary, rather than requiring the owner to reach into unrelated funds. This ties the usufructuary's compensation directly to the value of what he actually helped produce, rather than treating it as an open-ended claim against the owner generally.
Third-party rights are not affected
Article 567 closes with a limitation: the provisions of this article shall not prejudice the rights of third persons, acquired either at the beginning or at the termination of the usufruct. This means the ownership and reimbursement rules just described operate between the owner and the usufructuary, without overriding whatever legitimate rights a third party may already hold in the crops or the property at either of those two moments.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Juan De Delos Carlos vs. Felicidad Sandoval, et al, G.R. No. 179922, December 16, 2008 — read the decision on LawPhil →