Datalift Movers, Inc. v.

Belgravia Realty & Development Corporation

G.R. No. 144268; 30 August 2006; Garcia, J.
Digest by Ruth Guinto

FACTS
1987: The Philippine National Railways leased out a lot to Sampaguita Brokerage, Inc. pursuant to a
written contract with a monthly rental of Php 6,282.49, subject to 10% increase every year.

Sampaguita thereafter entered into a special arrangement with its sister company, Belgravia Realty
whereby the latter would put up on the lot a warehouse for its own use. Belgravia put up a warehouse,
but instead of using the warehouse for itself, Belgravia sublet it to Datalift, for a monthly rental of Php
40,000.

After the one year contract period expired, Datalift continued in possession and enjoyment of the leased
warehouse, by acquiesance of Belgravia or by verbal understanding. Belgravia unilaterally increased the
monthly rental to Php 60,000. Monthly rental was again increased to Php 130,000, allegedly in view of
the increased rental demanded by PNR on Sampaguita. Because of the rental increase, Datalift stopped
paying its monthly rental for the warehouse.

Thereafter, Sampaguita addressed demand letters to Datalift asking the latter to pay its rental in arrears
and to vacate and surrender the warehouse in dispute. These efforts proved futile, Belgravia and/or
Sampaguita filed with the MeTC of Manila a complaint for ejectment.

In their Answer with Counterclaim, Datalift raised the defense that Belgravia has no cause of action
because it was neither the owner nor lessee of the lot where the warehouse stands.

MeTC ruled in favor of Belgravia and Sampaguita but reduced the amount of rental arrearages. MeTC
rejected Datalift’s challenge against Belgravia’s title over the PNR lot occupied by the subject
warehouse.

Both parties appealed to the RTC. RTC affirmed the MeTC in toto.

Datalift elevated the case to the CA. CA dismissed the petition and affirmed with slight modification the
RTC decision.

Hence, this petition for review.

ISSUES
Whether or not Datalift has the personality to question whether an implied new lease was created
between PNR and respondents, Belgravia & Sampaguita. [NO]

RATIO
The Rules of Court sufficiently shields respondent Belgravia from being questioned by Datalift, regarding
its title or better right of possession as lessor because having admitted the existence of a lessor-lessee
relationship, Datalift is barred from assailing Belgravia’s title of better right of possession as their lessor.

Sec. 2 of Rule 131

 Conclusive presumptions. – xxx.
(b) The tenant is not permitted to deny the title of his landlord at the time of the
commencement of the relations of landlord and tenant between them.

Conclusive presumptions are inferences which the law makes so peremptory that it will not allow them
to be overturned by any contrary proof however strong. As long as the lessor-lessee relationship
between the Datalift and Belgravia exists, the former cannot by any proof however strong, overturn the
conclusive presumption that Belgravia has valid title to or better right of possession to the subject
leased premises than they have.

The logical consequence of the operation of the conclusive presumption is that Datalift will never have
the personality to question whether an implied new lease was created between PNR and the
respondents, Belgravia and Sampaguita.