Short answer. Yes. Civil Code Article 443 states that whoever receives the fruits is obligated to pay the expenses a third person incurred in producing, gathering, and preserving them. The owner cannot keep the fruits and avoid reimbursement for the costs that made those fruits available.
What the law says
He who receives the fruits has the obligation to pay the expenses made by a third person in their production, gathering, and preservation.
Civil Code, Article 443 — Expenses on Fruits. Read the full provision →
The reimbursement obligation is tied to receipt, not ownership
Article 443 focuses on who receives the fruits, not who owns the land. If you receive fruits — crops, produce, or other natural or civil fruits — that a third person raised at their own expense, you owe that person reimbursement for the costs of production, gathering, and preservation. The obligation runs with the benefit. Keeping the product of another's labour and expense without compensating them would be unjust enrichment. Article 443 prevents that by tying the reimbursement duty to the fact of receipt.
What counts as production, gathering, and preservation
The three categories — production, gathering, and preservation — cover the full lifecycle of bringing a fruit to the point where it can be received. Production expenses include planting, tending, fertilising, and all labour and inputs during growth. Gathering expenses cover harvesting, collecting, and transporting the crop from the field. Preservation expenses address post-harvest handling — drying, storage, and other steps to prevent spoilage before the product is turned over or used. All three categories of expense fall on the person who ultimately receives the fruits.
When this rule commonly comes up
This rule arises most often in property disputes where possession has changed hands. A person who was in possession of land, planted crops, and then lost possession when the real owner recovered the property may still have a claim for the expenses they spent on those crops. The real owner cannot take the harvest without settling those costs. It also appears in usufruct and agricultural tenancy situations — wherever the person who invested effort and money in producing a crop is not the same person who ends up with the product in hand.
Limits and what the rule does not cover
Article 443 covers only the expenses of producing, gathering, and preserving the fruits themselves. It does not automatically entitle the third party to a share of the profits or to compensation for improvements to the land, which are governed by other provisions. It also does not apply when the third person had no right to be on the land and raised the crops in bad faith — in that situation, other rules on the rights of a possessor in bad faith apply. Article 443 is the baseline for good-faith situations where someone's legitimate expenditure deserves compensation from the person who walks away with the benefit.
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.
- National Housing Authority vs. Manila Seedling Bank Foundation, G.R. No. 183543, June 20, 2016 — read the decision on LawPhil →