1.
In the analogous case of RICARDO QUIAMBAO vs. HON. ADRIANO OSORIO, ZENAIDA
GAZA BUENSUCERO, JUSTINA GAZA BERNARDO, and FELIPE GAZA, LAND AUTHORITY, G.R.
No. L-48157 March 16, 1988, the
Supreme Court discussed the effect of a PREJUDICIAL QUESTION vis-à-vis a
pending ejectment case.
1.1.
In
the said case the sole question was “whether
or not the administrative case between the private parties involving the lot
subject matter of the ejectment case constitutes a prejudicial question which
would operate as a bar to said ejectment case.”
1.2.
After
defining the general and specific concepts of “prejudicial question” as understood
in law, the Supreme Court held that although the two (2) actions involved in
the case at bar being respectively civil and administrative in character, and
thus, technically, there was no prejudicial question to speak of, nonetheless,
the Supreme Court held that the “intimate
correlation between said two [2] proceedings, stemming from the fact that the
right of private respondents to eject petitioner from the disputed portion
depends primarily on the resolution of the pending administrative case”.
1.3.
The
Supreme Court held therein:
“x x x.
X x x. For
while it may be true that private respondents had prior possession of the lot
in question, at the time of the institution of the ejectment case, such right
of possession had been terminated, or at the very least, suspended by the
cancellation by the Land Authority of the Agreement to Sell executed in their
favor.
Whether or not
private respondents can continue to exercise their right of possession is but a
necessary, logical consequence of the issue involved in the pending
administrative case assailing the validity of the cancellation of the Agreement
to Sell and the subsequent award of the disputed portion to petitioner. If the
cancellation of the Agreement to Sell and the subsequent award to petitioner
are voided, then private respondents would have every
right to eject
petitioner from the disputed area. Otherwise, private respondent's light of
possession is lost and so would their right to eject petitioner from said
portion.
X x x.”
1.4.
Thus,
the Supreme Court, in the said case, held that faced with these distinct
possibilities, “the more prudent
course for the trial court to have taken is to hold the ejectment proceedings
in abeyance until after a determination of the administrative case”. It
added:
“x x x.
X x x. Indeed,
logic and pragmatism, if not jurisprudence, dictate such move. To allow the
parties to undergo trial notwithstanding the possibility of petitioner's right
of possession being upheld in the pending administrative case is to needlessly
require not only the parties but the court as well to expend time, effort and
money in what may turn out to be a sheer exercise in futility. Thus, 1
Am Jur 2d tells us:
The court
in which an action is pending may, in the exercise of a sound discretion, upon
proper application for a stay of that action, hold the action in abeyance to
abide the outcome of another pending in another court, especially where the
parties and the issues are the same, for there is power inherent in every court
to control the disposition of causes on its dockets with economy of time and
effort for itself, for counsel, and for litigants. Where the rights parties to
the second action cannot be properly determined until the questions raised in
the first action are settled the second action should be stayed. 2
X x x.”
1.5.
The
Supreme Court also stated that “the
existence in the said case of the same considerations of identity of parties
and issues, economy of time and effort for the court, the counsels and the
parties as well as the need to resolve the parties' right of possession before
the ejectment case may be properly determined” justified the application
of the prejudicial question rule in the ejectment case.
