G.R. No. 171858 ; January 22, 2007
Remington Industrial Sales Corporation, Petitioner, vs. Chinese Young Men’s Christian Association of the Phil. Islands, doing business under the name Manila Downtown YMCA, Respondent.

FACTS

Petitioner Remington Industrial Sales Corporation (RISC) leased three units from respondent Manila Downtown YMCA. It used two ground floor units (964 and 966) as a combined office and passageway to a second-floor unit (963). After disputes arose, RISC filed a consignation case for the ground floor units and formally surrendered possession of them effective July 1, 1998, to which YMCA registered no objection. The consignation court declared the case closed. However, RISC padlocked the ground floor units and retained the keys, arguing it needed them for access to the still-occupied second-floor unit, for which it had obtained a judicial lease extension.
YMCA subsequently filed separate ejectment cases for the ground floor units, alleging RISC’s padlocking and refusal to surrender keys constituted unlawful withholding. The Metropolitan Trial Court (MeTC) ruled for YMCA, ordering RISC to vacate and pay rentals. The Regional Trial Court (RTC) reversed, holding that RISC’s act was one of self-preservation due to the lack of a passageway to its second-floor unit and that the surrender in the consignation case had already settled the issue of possession.

ISSUE

Whether RISC’s act of padlocking the surrendered ground floor units and retaining their keys constitutes unlawful detainer, justifying its ejectment and liability for back rentals.

RULING

Yes. The Supreme Court reinstated the MeTC decision, ruling that RISC was guilty of unlawful detainer. The legal logic is anchored on the nature of possession and the effects of surrender. RISC’s formal surrender of the ground floor units in the consignation case, accepted by YMCA without objection, terminated its right of possession. From that moment, any act impairing YMCA’s dominion, such as padlocking the doors and withholding the keys, constituted unlawful withholding. The Court emphasized that possession includes not just physical occupation but also the right to control and use the property. By preventing YMCA’s access, RISC effectively deprived the owner of its right to beneficial use and control, thereby retaining a form of possession contrary to its act of surrender.
The defense of needing a passageway to the second-floor unit was legally untenable. Any right to a passageway, which was never definitively granted by final judgment, pertains to the separate lease of Unit 963. It cannot justify the unilateral act of withholding possession of the already-surrendered and distinct ground floor units. The obligation to provide access, if it exists, is a separate issue from the possessory rights over the ground floor, which were conclusively relinquished. Consequently, RISC’s continued deprivation of YMCA’s control over the premises made it liable for reasonable compensation for use (back rentals) from the date of surrender until actual vacatur.