Chinese Young Men's Christian Association of the Philippine Islands v. Remington Steel Corporation
REITERATIONFacts
The Antecedents: Remington Steel Corporation (Remington) leased units from the Chinese Young Men's Christian Association of the Philippine Islands (YMCA). YMCA formally terminated the lease over second-floor unit 963. Remington filed a case for Fixing of Lease Period and YMCA filed an Unlawful Detainer case for unit 963. Remington also filed a Petition for Consignation of Rentals for ground floor units 964 and 966, and subsequently filed a Formal Surrender of the Leased Premises for these units, which YMCA did not object to. However, Remington continued to use units 964 and 966 as a passageway to unit 963 and retained the keys. Procedural History: The Metropolitan Trial Court (MeTC) extended the lease period for unit 963 and dismissed YMCA's ejectment complaint. Remington filed a Motion to Constitute Passageway, which was forwarded to the Regional Trial Court (RTC) on appeal. The RTC granted Remington a longer extension for unit 963 and ordered YMCA to provide a passageway. The Court of Appeals (CA) affirmed the lower courts' authority to fix lease periods but ordered Remington to vacate unit 963, noting Remington had moved to its own building. Meanwhile, YMCA filed two separate unlawful detainer complaints against Remington for ground floor units 964 and 966. The MeTC ordered Remington to vacate and pay rent, but the RTC reversed these decisions and dismissed the complaints. YMCA appealed to the CA. The CA dismissed YMCA's petition for review in CA-G.R. SP No. 74292 (involving unit 964) for failure to show proof of authority of the signatory to the Verification and Certification of Non-Forum Shopping. A subsequent resolution denied YMCA's motion for reconsideration. The Petition: YMCA filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's dismissal of its petition for review concerning unit 964.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for review for failure to submit proof of authority of the signatory to the Verification and Certification of Non-Forum Shopping, and whether the subsequent submission of a Secretary's Certificate cured the defect in the Certification Against Forum Shopping. Whether the doctrine of stare decisis applies to the present case.
Ruling
The Court GRANTS the petition, REVERSES and SETS ASIDE the CA Resolutions dated January 16, 2003 and July 29, 2003. The final Resolution dated August 31, 2007 of the Court in G.R. No. 171858 shall govern the rights of the parties concerning unit 964.
Ratio Decidendi
On the dismissal of the petition for review for failure to submit proof of authority and the subsequent submission of a Secretary's Certificate: The Court held that the Court of Appeals erred in dismissing outright YMCA's petition for review. While the requirements of a verified petition and a certification of non-forum shopping are mandatory, the rule on certification against forum shopping may be relaxed on grounds of substantial compliance or special circumstances. The Court cited several cases, including Shipside Incorporated v. Court of Appeals, Havtor Management Philippines Inc. v. National Labor Relations Commission, and General Milling Corporation v. National Labor Relations Commission, where the belated submission of proof of authority was considered substantial compliance. In this case, YMCA rectified its failure by attaching a Secretary's Certificate to its Motion for Reconsideration, attesting to the signatory's authority prior to the filing of the petition. The Court distinguished this from Spouses Melo v. Court of Appeals, which involved a total failure to append the required certifications. The Court found that the subsequent submission of the Secretary's Certificate constituted substantial compliance and cured the defect. The Court reiterated the doctrine that the rule on certification against forum shopping, while mandatory, is not jurisdictional and can be relaxed in instances of substantial compliance. The objective is to prevent forum shopping, and a strict interpretation that defeats this objective should be avoided. The Court noted that YMCA timely filed the Verification and Certification of Non-Forum Shopping, but merely failed to submit proof of the signatory's authority at the outset. The subsequent submission demonstrated that there was no intent to disregard the procedural requirements, thus warranting the relaxation of the rule. On the application of stare decisis: The Court applied the doctrine of stare decisis to the present case, referencing its final Resolution dated August 31, 2007 in G.R. No. 171858, which involved the same parties and substantially similar facts concerning unit 966. The Court found that Remington unlawfully withheld possession of the leased premises because its constructive delivery did not amount to an effective transfer of possession to YMCA. This precedent established that Remington's actions constituted an unlawful withholding of possession, and the Court found it necessary to apply the same ruling to unit 964, as the facts were substantially the same. The Court emphasized that stare decisis promotes certainty and stability in judicial decisions, and that like cases should be decided alike when the facts are substantially the same.
Main Doctrine
The failure to submit proof of authority of the signatory to the Verification and Certification of Non-Forum Shopping is not fatal and may be cured by substantial compliance, especially when the signatory's authority is subsequently proven through a Secretary's Certificate, and the petition was timely filed.