Bernardo v Bataclan Application of article 445

Bernardo bought a land. He then discovers that Bataclan, who has been previously authorized by the former owners,
had built improvements on said lot. Bernardo files a case to secure possession over the property.

Issue: Who owns the improvements made on said lot?

Held: SC said Bernardo, as he is the landowner, owns the property. The Civil Code confirms certain time-honored
principles of the law of property. One of these is the principle of accession whereby the owner of property acquires
not only that which it produces but that which is united to it either naturally or artificially.

Whatever is built, planted or sown on the land of another, and the improvements or repairs made thereon, belong
to the owner of the land.

TLDR: Article 445 would tell us that as a general rule, it is the land owner who owns the improvements made on his
land by a builder, planter, or sower.