Remington Industrial Sales Corp. v. Chinese Young Men's Christian Association
REITERATIONFacts
1. The Antecedents: Remington Industrial Sales Corporation (RISC) leased Units 964 and 966 on the ground floor and Unit 963 on the second floor of a building owned by the Chinese Young Men’s Christian Association of the Philippines Islands (Manila Downtown YMCA). RISC modified the ground floor units for use as an office, hardware store, and display shop, and these units also served as a passageway to the second-floor unit, which was used as a staff room. A dispute arose, leading RISC to sue the YMCA for fixing the lease period of the second-floor unit, while the YMCA filed an action to evict RISC from the same unit. Separately, RISC filed a petition for consignation of rentals for the ground floor units due to the YMCA's alleged refusal to accept payment. RISC later formally surrendered the ground floor units, and the consignation case was closed. Subsequently, the YMCA filed two separate ejectment cases against RISC for the ground floor units, alleging that RISC had not truly surrendered possession, had padlocked the doors, refused to surrender keys, and failed to pay rent. 2. Procedural History: The initial consolidated cases for fixing of lease period and ejectment were decided by the Metropolitan Trial Court (MeTC) of Manila, Branch 26, which dismissed the ejectment case and extended the lease for Unit 963 by three years. This decision was appealed to the Regional Trial Court (RTC) of Manila, Branch 30, which granted a longer extension and ordered the YMCA to provide a passageway. The YMCA appealed to the Court of Appeals (CA), which held that while the lower courts had authority to extend the lease, the continuation of the lease was no longer tenable and ordered RISC to vacate. Meanwhile, the two ejectment cases filed by the YMCA for the ground floor units were decided by separate MeTC branches. MeTC-Manila, Branch 17, ordered RISC to vacate Unit 966 and pay rent. On appeal, the RTC-Manila, Branch 25, reversed the MeTC decision, dismissing the ejectment case for Unit 966, finding that RISC's actions constituted self-preservation due to the lack of a passageway and that the issue of possession of the ground floor units had been resolved with finality in the closed consignation case. The YMCA appealed this RTC decision to the CA. 3. The Petition: The Court of Appeals, in its assailed Decision, reversed the RTC and reinstated the MeTC decision, holding that RISC failed to surrender possession of the disputed ground floor units despite its formal surrender, as it continued to exercise control and use them as a passageway. RISC's subsequent Motion for Reconsideration was denied. This Petition for Review on Certiorari under Rule 45 of the Rules of Court is filed by RISC, raising issues regarding whether its formal surrender of the ground floor units was effective, whether its continued use of the keys as a passageway was antithetical to surrender, and whether the YMCA was guilty of forum shopping. RISC seeks to set aside the CA's decision and reinstate the RTC's dismissal of the ejectment case.
Issue(s)
Whether RISC's formal surrender on July 1, 1998, of the ground floor units, coupled with YMCA's subsequent acts, constitutes effective surrender of those units, and whether the use by RISC's staff of the key of the ground floor door, their only passageway to the street, is antithetical to RISC's surrender of the ground floor units. Whether respondent YMCA is guilty of forum shopping.
Ruling
The Supreme Court granted the petition, set aside the Court of Appeals' Decision and Resolution, and reinstated and affirmed the Decision of the Regional Trial Court of Manila, Branch 25, which dismissed the unlawful detainer case for lack of merit.
Ratio Decidendi
On the effectiveness of surrender and use of the key: The Court held that RISC had effectively surrendered possession of Units 964 and 966 to the respondent. The 'Formal Surrender of Leased Premises' filed by RISC, effective July 1, 1998, to which the YMCA manifested 'No Objection,' demonstrated RISC's intention to relinquish possession. The Court considered the filing of this document as RISC's constructive delivery of the premises. Furthermore, RISC had actually emptied and vacated the leased premises on the stated date. Therefore, from July 1, 1998, the respondent could have legally and actually taken possession of Units 964 and 966 by simply removing the padlock. The Court found RISC's request for a passageway to be necessary for the adequate use of Unit 963, which lacked direct road access. Since the YMCA did not immediately construct a passageway, the RTC correctly found it understandable that RISC kept the key to the ground floor door as its only means of access to the road and its second-floor unit. This act was not antithetical to the surrender, as it was a consequence of the YMCA's inaction and RISC's need for access. The Court thus affirmed the RTC's dismissal of the unlawful detainer case and claim for back rentals. On the issue of forum shopping: The Court found that the respondent YMCA was not guilty of forum shopping. It clarified that forum shopping involves initiating multiple actions based on the same cause of action, seeking favorable judgments in different courts. The Court noted that while the parties and subject premises were the same as in a prior consignation case, the causes of action were distinct. The ejectment cases concerned the physical possession of the leased premises, whereas the consignation case dealt with the deposit of rents without a judicial ruling on possession. Since the elements of litis pendentia or res judicata were not present between the ejectment cases and the prior consignation case, the filing of the ejectment actions did not constitute forum shopping.
Main Doctrine
The formal surrender of leased premises, coupled with vacating the property and the lessor's failure to immediately resume possession or remove obstructions, can constitute effective surrender, even if the lessee retains a key for necessary access to another leased unit. The lessor's failure to provide a required passageway can justify the lessee's retention of the key for access.