GR L 2850; (December, 1949) (Digest)
G.R. No. L-2850. December 29, 1949.
ONG KIM PAN (alias PABLO ONG) and ONG WA, petitioners-appellants, vs. FRANCISCO GERONIMO, Judge of Municipal Court of Manila, and BENITO GONZALES, respondents-appellees.
FACTS
Petitioners-appellants are tenants of a building owned by respondent-appellee Benito Gonzales. After refusing to pay a rent increase and being given notice to vacate, the tenants filed actions for consignation and declaratory relief in the Court of First Instance to determine the lawful rent. Subsequently, the landlord filed ejectment (desahucio) cases in the Municipal Court based on the termination of the month-to-month lease. The Municipal Court initially suspended the ejectment cases but lifted the suspension after the consignation and declaratory relief actions were dismissed. The tenants then filed an action for prohibition in the Court of First Instance to restrain the trial of the ejectment cases, arguing that the other pending cases between the same parties involving the same subject matter warranted a stay. The Court of First Instance dismissed the prohibition action.
ISSUE
Whether the pendency of the consignation and declaratory relief cases warrants a stay of proceedings in the ejectment cases.
RULING
No. The Supreme Court affirmed the dismissal of the prohibition action. A stay of proceedings is discretionary and generally appropriate only where the judgment in the first action will res judicata the second action, disposing of all questions and the entire controversy. Here, the consignation and declaratory relief cases only address the amount of lawful rent, while the ejectment cases pose the distinct issue of whether the lease has terminated. A decision on the rent will not necessarily resolve the issue of ejectment. Furthermore, granting a stay in the ejectment cases would work injustice to the landlord by paralyzing the summary remedy of desahucio and allowing a circumvention of its purpose. The Municipal Judge properly exercised his discretion in denying the suspension.
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