G.R. No. 170509 ; June 27, 2012
Viegely Samelo, represented by Attorney-in-Fact Cristina Samelo, Petitioner, vs. Manotok Services, Inc., allegedly represented by Perpetua Bocanegra (deceased), Respondent.

FACTS

Manotok Services, Inc. (respondent) filed an unlawful detainer complaint against Viegely Samelo (petitioner) before the Metropolitan Trial Court (MeTC) of Manila. The respondent alleged it was the administrator of a parcel of land and had entered into a one-year lease contract with the petitioner for a portion thereof. After the lease expired on December 31, 1997, the petitioner continued occupying the premises without paying rent. Despite a demand letter sent on August 5, 1998, the petitioner refused to vacate and pay compensation.
In her defense, the petitioner claimed the respondent had no right to collect rent as the property was inside Philippine National Railways (PNR) land and the respondent lacked a certificate of title. She asserted ownership based on possession since 1944 and alleged her signature on the lease was obtained through misrepresentation. The MeTC ruled for the respondent, ordering the petitioner to vacate and pay rentals. The Regional Trial Court (RTC) reversed this, dismissing the complaint on grounds the respondent failed to prove its authority to administer the property. The Court of Appeals (CA) reinstated the MeTC decision, prompting the petitioner’s appeal to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in ruling that the petitioner, as a lessee, is estopped from denying the respondent’s title and in reinstating the judgment for unlawful detainer.

RULING

The Supreme Court denied the petition, affirming the CA decision with modification on interest. The core issue in an unlawful detainer case is physical possession (possession de facto), independent of claims of ownership. The petitioner, by entering into a lease contract, acknowledged the respondent’s better right of possession at that time. The principle of estoppel applies: a tenant cannot deny the landlord’s title or assert a right adverse to it without first surrendering possession. The petitioner’s continued occupancy after the lease expiry constituted unlawful withholding.
The Court clarified that while ownership may be provisionally resolved to determine possession, it is not required here as the petitioner’s status as a lessee was established by the contract. Her claim of ownership since 1944 and alleged repudiation of the lease, including a separate case for annulment, did not negate the respondent’s superior possessory right arising from the expired lease. The demand to vacate was valid, and the one-year period to file the ejectment suit was timely counted from the last demand. The unpaid rentals shall earn interest at 6% per annum from August 5, 1998, until finality of judgment, then at 12% until full satisfaction.