Exhibit 5.1

LOEB & LOEB LLP   345 Park Avenue
New York, NY 10154 Main 212.407.4000
Fax 212.407.4990

October 23, 2023

Revelstone Capital Acquisition Corp.

14350 Myford Road

Irvine, CA 92606

Ladies and Gentlemen:

We have acted as counsel to Revelstone Capital Acquisition Corp., a Delaware corporation (“Revelstone”), in connection with the preparation of a registration statement on Form S-4, File No. 333-274049, filed by Revelstone with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, with respect to the issuance of up to 12,203,000 shares of Class A common stock, par value $0.0001 of Revelstone (the “Merger Consideration Shares”) in connection with a business combination transaction (the “Business Combination”), pursuant to that certain Merger Agreement dated July 17, 2023, as amended on August 16, 2023 (the “Merger Agreement”), by and among Revelstone, Revelstone Capital Merger Sub, Inc., a Delaware corporation and a wholly owned subsidiary of Revelstone (“Merger Sub”), Set Jet, Inc., a Nevada corporation (“Set Jet”) and Thomas P. Smith, as securityholder representative. Pursuant to the terms of the Merger Agreement, the Business Combination between Revelstone and Set Jet will be effected through the merger of Merger Sub with and into Set Jet, with Set Jet surviving the Merger as a wholly owned subsidiary of Revelstone.

We have examined such documents and considered such legal matters as we have deemed necessary and relevant as the basis for the opinion set forth below. With respect to such examination, we have assumed the genuineness of all signatures, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as reproduced or certified copies, and the authenticity of the originals of those latter documents. As to questions of fact material to this opinion, we have, to the extent deemed appropriate, relied upon certain representations of certain officers of Revelstone.

Based upon the foregoing and subject to the limitations, qualifications and assumptions set forth herein, we are of the opinion that upon issuance in the Business Combination pursuant to the terms of the Merger Agreement, the Merger Consideration Shares will be validly issued, fully paid and non-assessable.

In addition, the foregoing opinion is qualified to the extent that (a) no opinion is expressed herein as to compliance with any federal or state consumer protection or antitrust laws, rules, or regulations, or any municipal or local laws and ordinances; and (b) no opinion is expressed herein as to compliance with or the effect of federal or state securities or blue sky laws.

We are admitted to practice in the State of New York, and we express no opinion as to any matters governed by any law other than the law of the State of New York and the General Corporation Law of the State of Delaware.

We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the reference made to us under the caption “Legal Matters” in the proxy statement/prospectus constituting part of the Registration Statement. In giving this consent, we do not thereby admit that we are within the category of persons whose consent is required under Section 7 of the Act, the rules and regulations of the Commission promulgated thereunder.

Very truly yours,

/s/ Loeb & Loeb LLP    

Loeb & Loeb LLP