G.R. No. 144268 - Datalift Movers, Inc. vs. Belgravia Realty and Development Corp.

Petitioners: Datalift Movers, Inc. and Jaime B. Aquino (president of Datalift)
Respondents: Sampaguita Brokerage, Inc. and Belgravia Realty & Development Corporation (sister companies)
The disputed property: a warehouse located on a 3,967.70 square meter lot owned by the Philippine National Railways (PNR), situated at No. 883 Santibañez Street corner Cristobal Street, Pandacan, Manila.

PNR leased the lot to Sampaguita Brokerage, Inc. starting July 1, 1987, expiring June 30, 1990, for a monthly rental of ₱6,282.49 with a 10% annual increase.
Sampaguita and Belgravia entered a special arrangement where Belgravia would build and use a warehouse on the lot. Belgravia constructed a warehouse occupying approximately 3,000 square meters.
Instead of using it for itself, Belgravia subleased the warehouse to Datalift via a 1-year written lease beginning October 5, 1990, with a monthly rental of ₱40,000 payable by the 15th of each month and advance rental for two months upon contract execution. The lease was subject to extension upon mutual agreement.

After the expiration of the one-year lease in 1991, Datalift remained in possession of the warehouse, apparently with Belgravia’s consent or by verbal agreement.
Belgravia unilaterally increased the monthly rent to ₱60,000 from June to October 1994 and further increased it to ₱130,000 starting November 1994, citing increased rental demands from PNR to Sampaguita.
Datalift stopped paying rent due to the rental increases.

Sampaguita sent demand letters to Datalift requesting payment of ₱4,120,000 in rental arrears and vacating of the warehouse.
Following failed demands, Sampaguita and/or Belgravia filed an ejectment complaint against Datalift and Jaime B. Aquino at the Metropolitan Trial Court (MeTC) of Manila.
Defendants raised these defenses:

Sampaguita had no cause of action as it was not a party or privy to the Datalift-Belgravia lease contract.
Sampaguita was prohibited from subleasing under its lease with PNR.
The lease between PNR and Sampaguita had allegedly expired.
Belgravia had no cause of action because it was neither owner nor lessee of the lot.

Defendants also counterclaimed for the refund of rentals paid, exemplary damages, and litigation expenses.

MeTC ruled in favor of Sampaguita and Belgravia, ordering ejectment and rental arrears payment, but reduced the rental arrears claim to ₱80,000/month as a reasonable amount (contrasting with the claimed ₱130,000).
MeTC rejected defendants’ challenge to Belgravia’s title or authority to sue.
Defendants were ordered to pay attorney’s fees and costs.

The Regional Trial Court (RTC) affirmed the MeTC decision in toto.
The Court of Appeals (CA) likewise affirmed the RTC decision but deleted the award of ₱30,000 attorney’s fees.
The petitioners elevated the case to the Supreme Court via a petition for review with application for temporary restraining order and/or preliminary injunction, contesting the validity of an implied lease between PNR and respondents, and their lack of personality to question such implied lease.

The Court affirmed the lower courts but modified the order on rental arrears payments: the increase to ₱130,000 was effective November 1994, not June 1994, thus no unpaid rental differential for June to October 1994.
Petitioners were ordered to pay unpaid rentals from November 1994 amounting to ₱80,000/month until they vacate.
The Court held that petitioners could not question Belgravia’s title or the alleged implied lease between PNR and respondents due to conclusive presumptions under Section 2, Rule 131 of the Rules of Court.

Whether the petitioners have the legal personality to question the existence of an implied new lease between PNR and Sampaguita/Belgravia and to challenge Belgravia’s title over the leased premises.
Whether the unilateral rental increases by Belgravia from ₱60,000 to ₱130,000 monthly starting June or November 1994 are valid and whether petitioners are liable for unpaid rental arrears based on said increased amounts.
Whether the ejectment order against petitioners and the award of unpaid rentals, attorney’s fees, and costs were proper.