G.R. No. 159422 - Chinese Young Men's Christian Association of the Philippine Islands vs. Remington Steel Corp.

The parties involved are the Chinese Young Men's Christian Association of the Philippine Islands doing business as Manila Downtown YMCA (YMCA) and Remington Steel Corporation (also referred to as Remington).
Remington leased several units in a building owned by YMCA: ground floor units 964 and 966 and second floor unit 963.
The leased ground floor units were used as a hardware store, offices, and display shops for steel products, and they also formed a passageway to the second floor unit which served as a staff room for Remington’s sales force.

On February 27, 1997, YMCA terminated the lease over second floor unit 963 and provided Remington until March 31, 1997 to vacate the premises.
Remington filed a case for the Fixing of Lease Period over unit 963 in the Metropolitan Trial Court (MeTC) on March 24, 1997 (Civil Case No. 154969-CV).
Subsequently, YMCA filed an action for Unlawful Detainer involving the same unit (Civil Case No. 155083-CV), and the cases were consolidated before MeTC-Branch 26.

During the pendency of the aforementioned cases, Remington filed a Petition for Consignation of Rentals (Civil Case No. 155897, MeTC-Branch 24) on the ground that YMCA refused to receive rentals for the ground floor units.
On June 23, 1998, Remington formally surrendered units 964 and 966, effective July 1, 1998, and tendered checks covering all past rentals.
Although YMCA initially indicated no objection to the turnover, Remington continued to use the ground floor units as a passageway to the second floor and kept these premises padlocked, failing to deliver the keys to YMCA.

In August 1998, MeTC extended the lease period in Civil Case Nos. 154969-CV and 155083-CV for unit 963, while dismissing the ejectment complaint of YMCA.
Remington invoked the need to constitute a passageway, filing a Motion to Constitute Passageway in MeTC-Branch 26, which led to an ocular inspection revealing that YMCA’s failure to provide an adequate passageway kept Remington in possession of the keys to the ground floor units.
The unresolved issue of the passageway was forwarded to RTC-Branch 30, which, in a decision dated March 15, 2000, granted Remington a five-year extension for unit 963 and ordered YMCA to construct a two-meter passageway between units 964 and 966.

Dissatisfied with the RTC decision, YMCA filed an appeal with the Court of Appeals (CA) under CA-G.R. SP No. 58957, where the CA acknowledged that although the original lease had expired, a new month-to-month lease had effectively been established. Despite ordering Remington to vacate the premises after six years, the CA noted Remington’s continued use and later vacating of the premises.
Parallel to these proceedings, YMCA initiated two separate complaints for unlawful detainer for the ground floor units (Civil Case Nos. 168629-CV and 168628-CV) before MeTC-Manila. These cases were initially consolidated but later reversed and tried separately, with both branches eventually ordering Remington to vacate and pay reasonable rent plus attorney’s fees.
Remington appealed these unlawful detainer decisions to the RTC, which reversed the MeTC rulings and dismissed YMCA’s complaints. YMCA then filed separate motions for reconsideration and subsequent petitions for review with the CA.

On January 16, 2003, the CA dismissed YMCA’s petition for review (CA-G.R. SP No. 74292) outright on the ground that the Verification and Certification of Non-Forum Shopping lacked proof of authority of its signatory, William Golangco.
YMCA subsequently filed a Motion for Reconsideration on February 10, 2003, appending a Secretary’s Certificate dated December 26, 2002, which attested to a Board of Directors’ resolution authorizing Golangco to sign the petition.
The CA, in its Resolution dated July 29, 2003, denied this motion, emphasizing the mandatory nature of attaching proof at the time of filing and referencing Spouses Melo v. Court of Appeals.

In separate proceedings involving Remington’s continued occupation of the premises, courts ruled on the issues of constructive delivery versus actual turnover.
The Supreme Court, in a later case (G.R. No. 171858), concluded that Remington’s constructive delivery by padlocking the premises without surrendering the keys did not effectively transfer possession to YMCA.
Consequently, YMCA was entitled to claim reasonable compensation for Remington’s unauthorized use from July 1, 1998, until March 12, 2004.
The Resolution dated August 31, 2007 in G.R. No. 171858 declared a compensation of P11,000.00 per month as equitable and binding, which later formed the controlling precedent for the instant case.

YMCA’s present petition challenges the CA’s dismissal of its petition for review for unit 964, arguing that the subsequent submission of a Secretary’s Certificate should cure the defect of failing to attach proof of authority at the time of filing.
Remington argued that the required proof of authority must be submitted with the petition initially to avoid encouraging procedural laxity.
The Court, in resolving the issue, considered not only the technical aspects of filing but also the fundamental principles of substantial compliance and the purpose of the Rules of Court.

Whether the failure to submit proof of authority of the signatory to the Verification and Certification of Non-Forum Shopping at the time of filing the petition for review constitutes a ground for its outright dismissal.
Whether the subsequent submission of a Secretary’s Certificate, attesting to the signatory’s authority, can cure the defect in the original filing.

Whether Remington’s act of padlocking the premises without turning over the keys amounts to a valid construct of delivery or if it constitutes unlawful withholding of possession.
Whether YMCA is entitled to recover reasonable compensation for the continued use and occupancy of the leased premises following the termination of the formal lease.

Whether the controlling doctrine of substantial compliance and stare decisis should lead the Court to apply the ruling in G.R. No. 171858, given the similarities in facts between the cases (the only difference being the unit involved).