G.R. No. 48569; October 23, 1942
FULGENCIO SIDECO, petitioner, vs. JOSE MA. PAREDES, ET AL., respondents.

FACTS

The petitioner, Fulgencio Sideco, was sued separately by sixteen of his tenants to recover a share in sugar benefit payments. Fourteen plaintiffs claimed P82.18 each, and two claimed P164.36 each. The cases were jointly tried in both the justice of the peace court of Santa Ana, where the defendant prevailed, and the Court of First Instance of Pampanga, where the plaintiffs prevailed. Petitioner moved to consolidate the sixteen cases for appeal to minimize expenses, tendering one record on appeal and one appeal bond. The respondent judge denied the motion to consolidate on the ground that it was filed too late and disapproved the consolidated record on appeal.

ISSUE

Whether the respondent judge erred in denying the motion to consolidate the sixteen cases for purposes of appeal.

RULING

The Supreme Court granted the petition. The sixteen cases involve a common question of law, as evidenced by their joint trial and single decision. Section 1 of Rule 32 allows consolidation when actions involving a common question of law or fact are pending, and it fixes no deadline for such consolidation. The joint trial effectively consolidated the cases for the convenience of the court and parties. The Rules of Court should be liberally construed to promote a just, speedy, and inexpensive determination of proceedings (Rule 1, Section 2). Consolidation would obviate the necessity of filing multiple appeal bonds, as a single bond would suffice once consolidation is allowed. Therefore, the petitioner is entitled to have the cases consolidated for appeal. The orders denying consolidation and reconsideration were set aside, and the Court of First Instance of Pampanga was directed to approve the consolidated record on appeal and the appeal bond.