Evicting a tenant who has stopped paying rent in the Philippines is not as simple as changing the locks, cutting utilities, or removing the tenant’s belongings. Even when the tenant clearly owes rent, Philippine law generally requires the landlord to make a proper demand, observe any required barangay conciliation, file an ejectment case in the correct first-level court, and obtain a court order before the tenant can be physically removed. This guide explains the lawful process for evicting a tenant for nonpayment, the documents you need, the timelines to expect, and the mistakes that commonly cause landlords to lose time in court.

What “eviction for nonpayment” means in the Philippines

In Philippine practice, the usual court case for removing a tenant who originally entered the property lawfully but later stopped paying rent is called unlawful detainer.

Unlawful detainer is different from forcible entry:

Situation	Usual case	Example
The person entered the property without your permission, by force, intimidation, strategy, threat, or stealth	Forcible entry	Someone breaks into or occupies your vacant property
The person entered lawfully but later lost the right to stay	Unlawful detainer	A tenant stops paying rent and refuses to leave after demand

For nonpayment of rent, the tenant’s possession usually started legally because of a lease, verbal agreement, written contract, or the landlord’s tolerance. It becomes unlawful only after the tenant violates the lease and refuses to pay or vacate despite proper demand.

This is why documentation matters. Courts do not only ask, “Does the tenant owe rent?” They also ask:

Was there a lease or landlord-tenant relationship?
How much rent is unpaid?
Was there a valid demand to pay and vacate?
Was the demand properly served?
Was barangay conciliation required?
Was the case filed within the required period?
Is the case filed in the correct court?

In the Philippines, ejectment cases are handled by first-level courts: the Metropolitan Trial Court, Municipal Trial Court in Cities, Municipal Trial Court, or Municipal Circuit Trial Court, depending on the location of the property. The Supreme Court’s 2022 Rules on Expedited Procedures place forcible entry and unlawful detainer cases under summary procedure in first-level courts. (Supreme Court of the Philippines)

Legal basis for evicting a tenant who does not pay rent

The tenant’s duty to pay rent

Under Article 1657 of the Civil Code, the lessee is obliged to pay the price of the lease according to the terms stipulated. The tenant must also use the leased property as a diligent person would, according to the purpose intended by the parties. (Lawphil)

If the tenant does not pay rent, the landlord may have grounds to terminate the lease and seek ejectment. Article 1673 of the Civil Code specifically allows the lessor to judicially eject the lessee for, among other grounds, lack of payment of the price stipulated. (Lawphil)

The key word is judicially. The landlord’s remedy is to go through the court process, not to personally force the tenant out.

The landlord’s obligations also matter

The landlord must also comply with the lease and the Civil Code. Article 1654 requires the lessor to deliver the leased property in a condition fit for its intended use, make necessary repairs unless otherwise agreed, and maintain the lessee in peaceful and adequate enjoyment of the lease. (Lawphil)

This matters because tenants sometimes defend nonpayment by claiming that the landlord failed to make essential repairs, refused access, interfered with possession, or otherwise breached the lease. Article 1658 also provides that the lessee may suspend payment if the lessor fails to make necessary repairs or maintain peaceful and adequate enjoyment. (Lawphil)

That does not mean every complaint by a tenant automatically excuses nonpayment. But if the landlord has unresolved repair issues, utility disputes, or harassment allegations, those issues can complicate the ejectment case.

Rent Control Act rules for covered residential units

For residential leases, the Rent Control Act of 2009, Republic Act No. 9653, may also apply.

RA 9653 covers certain residential units such as apartments, houses and land on which another’s dwelling is located, dormitories, rooms, and bedspaces, subject to rent thresholds and later government adjustments. (Lawphil)

For covered residential units, one statutory ground for judicial ejectment is arrears in payment of rent for a total of three months. RA 9653 also gives tenants a procedure for depositing rent if the landlord refuses to accept payment. (Lawphil)

For 2025 and 2026, current rent control policy is set by the National Human Settlements Board under the Department of Human Settlements and Urban Development. DHSUD has identified NHSB Resolution No. 2024-01 as the rent control issuance covering January 1, 2025 to December 31, 2026. (Human Settlements and Urban Development) DHSUD also announced that covered residential units with monthly rent of ₱10,000 and below are subject to rent increase limits for the same tenant, with a 2.3% cap for 2025 and a 1% cap for 2026, subject to the details of the resolution. (Philippine Information Agency)

Practical meaning:

If the unit is a covered residential unit, check RA 9653 and the current NHSB rent control rules.
If the unit is not covered by rent control, the Civil Code and the lease contract are usually the main bases.
For commercial spaces, higher-rent residential units, warehouses, offices, and special leases, the exact contract terms become especially important.

What landlords should not do

Even if the tenant has not paid for months, landlords should avoid “self-help eviction.” This includes:

Changing the locks while the tenant is out
Padlocking the gate or unit
Removing the tenant’s belongings
Cutting electricity, water, internet, or access to common areas to force the tenant out
Threatening the tenant or sending people to intimidate them
Entering the unit without consent except as clearly allowed by the lease and law
Publicly shaming the tenant online or in the barangay

Philippine law protects possession through legal process. Article 539 of the Civil Code states that every possessor has a right to be respected in possession and, if disturbed, to be protected or restored by legal means. (Lawphil) The Supreme Court has repeatedly emphasized that ejectment rules exist to prevent parties from taking the law into their own hands and to preserve peaceable possession until the court determines who has the better right to physical possession. (Lawphil)

Self-help eviction can backfire. Depending on what happened, the landlord may face civil claims, damages, barangay complaints, criminal complaints, or a separate case to restore possession. In extreme cases involving threats, intimidation, forced removal, or demolition, the issue may even be framed as grave coercion under Article 286 of the Revised Penal Code, as amended. (Lawphil)

The safer rule is simple: document the default, demand payment and vacating properly, then use the court process.

Step-by-step guide: how to evict a tenant for nonpayment

1. Review the lease contract and rent history

Before sending a demand letter, gather and review:

Written lease contract, if any
Text messages, emails, or chat records confirming the rental arrangement
Receipts, invoices, bank transfers, GCash or Maya records
Ledger showing monthly rent, due dates, payments, and unpaid balances
Security deposit and advance rent records
Utility bills, association dues, parking charges, or penalties if claimed
Move-in inventory or photos, if damages are also an issue

Check the lease for:

Rent amount and due date
Grace period
Penalty or interest clause
Notice period before termination
Address for notices
Renewal or holdover terms
Attorney’s fees clause
Venue or dispute resolution clause
Rules on subleasing, occupants, pets, commercial use, or damage

If there is no written lease, you can still pursue ejectment if you can prove the lease through receipts, messages, witnesses, or the tenant’s own admissions. A written contract is helpful, but it is not always required.

2. Check whether the property is covered by rent control

For residential properties, ask:

Question	Why it matters
Is the unit used as a dwelling?	RA 9653 applies to residential units, not ordinary commercial leases.
What is the monthly rent?	Current rent control rules focus on lower-rent units.
Is the same tenant continuing or renewing?	Rent increase caps usually apply to the same tenant, not necessarily to a newly vacant unit.
How many months of rent are unpaid?	For covered residential units, three months of rent arrears is a statutory ejectment ground.
Did the landlord refuse rent?	RA 9653 allows the tenant to deposit rent in certain situations if the landlord refuses to accept payment.

Do not assume every rental property follows the same rule. A ₱7,000 room rental, a ₱25,000 condo lease, a commercial stall, and a warehouse lease may involve different considerations.

3. Send a written demand to pay and vacate

For nonpayment cases, the demand letter is one of the most important documents.

Under Rule 70, a lessor generally cannot file an ejectment case for failure to pay rent or comply with lease conditions unless there has first been a demand to pay or comply and to vacate, and the tenant fails to comply after the required period. The Supreme Court has described prior demand as jurisdictional in unlawful detainer cases based on nonpayment or non-compliance. (Supreme Court E-Library)

A good demand letter should state:

Name of landlord and tenant
Complete address of the leased property
Date and basis of the lease
Monthly rent and due date
Exact unpaid months and total arrears
Any unpaid utilities, association dues, or other charges
Demand to pay the unpaid amount
Demand to vacate if payment is not made
Deadline for compliance
Reservation of the landlord’s right to file ejectment and claim damages, attorney’s fees, and costs

Rule 70 recognizes minimum waiting periods after demand: 15 days for land or 5 days for buildings, unless the contract provides otherwise. (Supreme Court E-Library) In practice, many landlords use a clear 15-day written demand even for units or buildings to avoid arguments about premature filing, but the correct approach should match the property, lease, and facts.

4. Serve the demand letter properly

The demand is only useful if you can prove service.

Common ways to serve a demand letter include:

Method	Practical notes
Personal delivery to tenant	Ask the tenant to sign receiving copy with date.
Delivery through messenger or representative	The server should later be able to execute an affidavit of service.
Registered mail or courier	Keep tracking number, registry receipt, delivery proof, and returned envelope if refused or unclaimed.
Email or messaging app	Useful as additional proof, especially if the lease allows electronic notices, but do not rely on it alone if formal service is disputed.
Posting on the premises	Rule 70 allows written notice to be served by posting if no person is found on the premises, but document this carefully. (Supreme Court E-Library)

If the tenant refuses to receive the letter, do not argue or force it into their hands. Record the refusal in an affidavit, use registered mail or courier, and preserve proof of attempted service.

5. Go through barangay conciliation if required

Before going to court, determine whether the dispute must first go through the Katarungang Pambarangay system.

Barangay conciliation may be required when the parties are natural persons residing in the same city or municipality, subject to the exceptions under the Local Government Code and Supreme Court administrative issuances. The Supreme Court’s guidelines identify barangay conciliation as a precondition for disputes covered by the system, with exceptions such as cases involving juridical entities, parties residing in different cities or municipalities, urgent legal actions, and other excluded disputes. (Lawphil)

In practical terms:

If both landlord and tenant are individuals living in the same city or municipality, expect the court to ask about barangay conciliation.
If the landlord is a corporation, partnership, condominium corporation, or property company, barangay conciliation may not apply because juridical entities are generally excluded.
If the parties live in different cities or municipalities, barangay conciliation may not be required, subject to specific rules and exceptions.
If barangay conciliation is required and no settlement is reached, obtain a Certificate to File Action.

A common mistake is filing immediately in court when barangay conciliation was required. This may cause dismissal, suspension, or referral back to the barangay, wasting time.

6. Prepare the ejectment complaint

The ejectment complaint should be filed in the first-level court of the city or municipality where the property is located.

For unlawful detainer, the complaint usually alleges:

The landlord owns, administers, or has authority over the property.
The tenant entered the property through a lease or permission.
The tenant failed to pay rent.
The landlord made a proper demand to pay and vacate.
The tenant failed or refused to comply.
The tenant’s continued possession is unlawful.
The complaint is filed within the required one-year period from unlawful withholding or last demand.

The Supreme Court’s Rules on Expedited Procedures require more than a bare complaint. The initiating pleading in summary procedure must attach the parties’ evidence, including judicial affidavits and documentary or object evidence, as required by the rules. (Supreme Court of the Philippines)

Typical attachments include:

Lease contract
Proof of ownership or authority to lease
Rent ledger or statement of account
Receipts and payment records
Demand letter
Proof of service of demand
Barangay Certificate to File Action, if applicable
Judicial affidavits of landlord, property manager, messenger, or other witnesses
Photos, inspection reports, or inventory if claiming damage
Special power of attorney, board resolution, or secretary’s certificate if filed by a representative

7. File in the correct court and pay the assessed fees

Ejectment cases are filed in the appropriate first-level court, not the Regional Trial Court, even if the unpaid rent is large. Under the 2022 Rules on Expedited Procedures, forcible entry and unlawful detainer cases fall under summary procedure regardless of the amount of damages or unpaid rentals, although attorney’s fees awarded by the court in these cases are capped at ₱100,000. (Supreme Court of the Philippines)

For filing fees, the Office of the Court Administrator has clarified that ejectment cases with no claim for damages or costs have a basic filing fee of ₱500. If the landlord claims interests, penalties, surcharges, damages, attorney’s fees, or other amounts, additional filing fees are assessed based on the amount claimed. (Office of the Court Administrator)

The clerk of court will assess the exact amount. Expect possible additional costs for service of summons, sheriff’s expenses, mediation-related fees, and certified copies.

8. Wait for summons, answer, mediation, and judgment

After filing, the court issues summons to the tenant. Under the Rules on Expedited Procedures, the defendant must file an answer within 30 calendar days from service of summons and serve a copy on the plaintiff. (Supreme Court of the Philippines)

If the tenant fails to answer, the court may render judgment based on the complaint and attachments, limited to what the landlord prayed for. (Supreme Court of the Philippines)

If an answer is filed, the case generally proceeds through:

Preliminary conference
Mandatory court-annexed mediation
Possible judicial dispute resolution
Submission of position papers or clarificatory evidence, if required
Judgment

The rules allow judicial dispute resolution within a short, inextendible period after failed mediation, and require parties or properly authorized representatives to appear at preliminary conference. Representatives must have authority to settle, enter into alternative modes of dispute resolution, make admissions, and enter into stipulations. (Supreme Court of the Philippines)

If the court requires position papers, they must be submitted within 10 calendar days from receipt of the order. The court is then directed to render judgment within the periods stated in the rules, such as 30 calendar days from receipt of the mediator’s or JDR report, or after submission of required clarificatory evidence. (Supreme Court of the Philippines)

9. Enforce the judgment through the sheriff

Winning the case does not mean the landlord may personally remove the tenant. Physical eviction is done through legal execution, usually with the sheriff.

If the landlord wins, the court may order the tenant to:

Vacate the property
Pay unpaid rentals or reasonable compensation for use and occupancy
Pay attorney’s fees, if awarded and proper
Pay costs of suit
Pay damages, if proven and prayed for

If the tenant appeals, ejectment judgments in favor of the plaintiff are generally immediately executory unless the tenant properly stays execution. Supreme Court doctrine states that the tenant must generally perfect the appeal, file a supersedeas bond, and deposit current rentals or reasonable compensation during the appeal; failure to comply may allow execution despite appeal. (Lawphil)

Under the 2022 Rules on Expedited Procedures, appeal from a first-level court judgment is taken by notice of appeal within 15 calendar days, and the Regional Trial Court’s judgment on appeal is final, executory, and unappealable under the rule. (Supreme Court of the Philippines)

In real life, the execution stage can still take time because of motions, sheriff scheduling, coordination with barangay officials or police for peacekeeping, inventory of belongings, and resistance by occupants.

Documents checklist for landlords

Document	Why it matters
Lease contract	Proves rent amount, due date, term, penalties, notice rules, and tenant obligations
Proof of ownership or authority	Shows the landlord or representative has legal standing to sue
Rent ledger or statement of account	Clearly shows unpaid months and running balance
Receipts and bank records	Prevents disputes over payments already made
Demand letter to pay and vacate	Usually essential in nonpayment unlawful detainer cases
Proof of service of demand	Shows the court the tenant received, refused, or was properly served with notice
Barangay Certificate to File Action	Needed if barangay conciliation applies
Judicial affidavits	Required evidence under summary procedure
Photos or inspection reports	Useful if claiming property damage or misuse
Special power of attorney	Needed if an agent, relative, property manager, or lawyer-in-fact signs or appears
Board resolution or secretary’s certificate	Needed if the landlord is a corporation or juridical entity
Computation of deposits and advances	Helps address whether deposit was applied to rent, utilities, or damage
Utility and association dues records	Needed if those amounts are claimed as part of arrears

Practical timelines and costs

Actual timelines vary by city, court docket, service of summons, mediation, appeals, and tenant resistance. Still, landlords can use the following as a practical guide.

Stage	Typical timing in practice	Notes
Preparing records and demand letter	A few days to 1 week	Faster if documents are organized
Demand period	5 or 15 days minimum depending on property and facts	Many landlords use a clearer written deadline to avoid disputes
Barangay conciliation, if required	Often 2 to 6 weeks	Depends on attendance, settlement talks, and issuance of certificate
Filing and summons	A few weeks to several months	Service of summons is a common bottleneck
Tenant’s answer	30 calendar days from service of summons	Required under expedited procedure
Mediation, preliminary conference, JDR	Several weeks to a few months	Settlement can shorten the case
Judgment in a straightforward case	Often 2 to 6 months from filing if uncontested or smooth	Court workload matters
Contested case with appeal and execution	Often 6 to 18 months or longer	Delays often arise from service, motions, appeal, and sheriff execution

For costs, the filing fee may start at ₱500 if no damages or costs are claimed, but additional fees apply when claiming back rent, damages, penalties, attorney’s fees, and other monetary relief. (Office of the Court Administrator) Attorney’s fees, notarization, courier, sheriff-related expenses, certified copies, and representation costs are separate practical expenses.

Common problems in tenant eviction cases

The tenant pays part of the arrears after receiving demand

Partial payment can complicate the case if the landlord accepts it without clear reservation.

For example, if the tenant owes ₱90,000 and pays ₱10,000 after demand, the landlord should document whether the payment is accepted only as partial payment and not as a waiver of the right to terminate or eject. Without clear documentation, the tenant may argue that the landlord allowed the lease to continue.

A written acknowledgment should state:

Amount received
Months or charges covered
Remaining balance
Whether the landlord still demands full payment and vacating
Whether acceptance is without prejudice to ejectment

The lease expired but the tenant kept paying

Article 1669 of the Civil Code provides that a fixed-term lease ceases upon the day fixed without need of demand. However, Article 1670 states that if the tenant continues enjoying the property for 15 days with the landlord’s acquiescence and no prior contrary notice, an implied new lease may arise, subject to the terms of the original contract except the lease period. (Lawphil)

This is important because landlords sometimes let a tenant stay after expiration while accepting rent. That can change the legal theory from simple expiration to implied renewal or month-to-month occupancy.

The landlord has no written lease

No written lease does not automatically defeat eviction. Courts can consider:

Rent receipts
Bank transfers
Text messages or emails
Admission by the tenant
Witness testimony
Utility records
Prior demands or acknowledgments

The bigger problem is usually proving the rent amount, due dates, and unpaid balance. If there is no written lease, organize the payment history carefully.

The tenant refuses to receive notices

A tenant cannot usually defeat the case simply by refusing to accept a demand letter. But the landlord must prove proper service or attempted service.

Use multiple methods:

Personal service with witness
Registered mail or courier
Email or messaging app as supplemental notice
Posting on the premises when legally appropriate
Affidavit from the person who served or posted the demand

Courts look for credible, specific proof, not vague statements like “tenant was notified.”

The landlord is abroad or an OFW

A landlord outside the Philippines can authorize someone in the Philippines to act through a Special Power of Attorney.

The SPA should specifically authorize the representative to:

Sign and serve demand letters
Attend barangay conciliation
File and sign pleadings, including verification and certification against forum shopping when appropriate
Execute judicial affidavits if based on personal knowledge
Attend mediation and preliminary conference
Enter into settlement
Make admissions and stipulations if intended
Coordinate with the sheriff for execution

If executed abroad, the SPA may need consular notarization at a Philippine Embassy or Consulate, or an apostille if executed in a country that is part of the Apostille Convention. Philippine foreign service posts explain that documents executed abroad may be notarized through the nearest Philippine Embassy or Consulate or apostilled through the proper foreign authority, depending on the country. (Philippine Embassy in New Delhi)

This is not just paperwork. Under the expedited procedure rules, a representative who attends preliminary conference must have specific authority to settle, enter into ADR, make admissions, and enter stipulations; otherwise, the appearance may be treated as ineffective. (Supreme Court of the Philippines)

The tenant is a foreigner

A foreign tenant is generally subject to the same lease and ejectment rules as a Filipino tenant. The practical issues are usually:

Whether the foreigner is still physically in the Philippines
Whether summons can be served
Whether other occupants remain in the unit
Whether the lease was signed by the foreigner personally or through a company
Whether the foreigner left belongings behind
Whether immigration status is being improperly used as pressure

Eviction is a property possession issue, not an immigration shortcut. A landlord should focus on rent records, demand, proper service, court judgment, and sheriff execution.

The landlord wants to use the security deposit

Under RA 9653, for covered residential units, the lessor cannot demand more than one month advance rent and more than two months deposit, and the deposit may answer for unpaid rent, utility bills, and damage caused by the tenant, commensurate to the amount due. (Lawphil)

Even if the deposit can be applied, it does not automatically give the landlord the right to lock out the tenant. Apply the deposit transparently in the statement of account and demand the remaining balance if any.

The property was sold or mortgaged

For covered residential units, RA 9653 states that no lessor or successor-in-interest may eject the tenant on the ground that the leased property has been sold or mortgaged. (Lawphil)

This does not mean a tenant may live rent-free after sale. It means sale or mortgage alone is not a proper ground for ejectment under that law. The new owner or authorized lessor may still need to rely on valid grounds such as nonpayment, expiration, or other lawful causes.

Frequently Asked Questions

Can a landlord evict a tenant immediately for not paying rent?

No. Even if the tenant has not paid, the landlord generally must make a proper demand, comply with barangay conciliation if required, file an ejectment case, obtain judgment, and enforce the judgment through the sheriff. Self-help eviction is risky and can create legal problems for the landlord.

How many months of unpaid rent before a tenant can be evicted in the Philippines?

For residential units covered by the Rent Control Act, arrears totaling three months are a statutory ground for judicial ejectment. (Lawphil) For units not covered by rent control, the lease contract and Civil Code are important; nonpayment is a ground for judicial ejectment under Article 1673, but the landlord must still follow proper demand and court procedure. (Lawphil)

Is a demand letter required before filing ejectment?

For nonpayment or breach of lease conditions, yes, a demand to pay or comply and to vacate is generally required before filing unlawful detainer. Rule 70 requires demand and a waiting period, and the Supreme Court has treated prior demand as jurisdictional in unlawful detainer cases based on nonpayment or non-compliance. (Supreme Court E-Library)

Can I change the locks if the tenant refuses to leave?

No. Changing locks to force a tenant out is a form of self-help eviction and may expose the landlord to civil, barangay, or criminal complaints depending on the circumstances. The lawful route is to obtain a court judgment and have eviction implemented by the sheriff.

Do I need to go to the barangay before court?

Sometimes. Barangay conciliation may be required if the landlord and tenant are natural persons residing in the same city or municipality and no exception applies. It is usually not required when a party is a corporation or other juridical entity, when parties reside in different cities or municipalities, or when another exception applies. (Lawphil)

What if the tenant has no written lease?

You may still file an ejectment case if you can prove the rental arrangement and nonpayment through receipts, bank records, messages, witnesses, or other evidence. The absence of a written lease makes documentation more important, especially for proving the rent amount, due dates, and unpaid balance.

Can the tenant stop eviction by paying the unpaid rent?

Payment may help the tenant negotiate or settle, but it does not always automatically erase the landlord’s right to proceed, especially if the lease has been validly terminated or there are repeated defaults. The effect depends on the lease, the demand, the timing of payment, whether the landlord accepted payment with reservation, and whether the court approves any settlement.

How long does eviction take in the Philippines?

A straightforward uncontested ejectment case may take a few months, but contested cases can take much longer, especially if there are problems with summons, barangay conciliation, mediation, appeal, or sheriff execution. A practical range is often 2 to 6 months for smoother cases and 6 to 18 months or more for heavily contested cases.

Can I recover unpaid rent and attorney’s fees in the ejectment case?

Yes, unpaid rentals or reasonable compensation for use and occupancy may be claimed in the ejectment case. Attorney’s fees and damages may also be claimed if legally and factually supported, but the correct filing fees must be paid based on the amounts claimed. Under the expedited procedure rules, attorney’s fees awarded in ejectment cases are capped at ₱100,000. (Supreme Court of the Philippines)

What happens if the tenant appeals?

A tenant may appeal within the period allowed by the rules. However, ejectment judgments in favor of the landlord are generally immediately executory unless the tenant properly stays execution by complying with requirements such as appeal, supersedeas bond, and rental deposits during appeal. (Lawphil) Under the expedited procedure rules, the Regional Trial Court judgment on appeal is final, executory, and unappealable. (Supreme Court of the Philippines)

Key Takeaways

A tenant who entered lawfully but stopped paying rent is usually removed through an unlawful detainer case.
Nonpayment of rent is a ground for judicial ejectment under Article 1673 of the Civil Code.
For covered residential units, RA 9653 provides specific rent control rules, including three months of arrears as a ground for judicial ejectment.
Do not change locks, cut utilities, remove belongings, or threaten the tenant. Use the court process.
A written demand to pay and vacate is usually essential in nonpayment cases.
Barangay conciliation may be required before court, depending on the parties and residence.
Ejectment cases are filed in the first-level court where the property is located and are governed by expedited summary procedure.
Strong documentation—lease, ledger, demand letter, proof of service, barangay certificate, and judicial affidavits—often determines how smoothly the case proceeds.
If the landlord wins, physical eviction is enforced by the sheriff, not personally by the landlord.
Appeals do not automatically stop execution unless the tenant complies with the legal requirements to stay execution.