Can a judgment of the small claims court preclude a subsequent judgment from the same cause of action?

In Sanderson v. Niemann (1941) 17 Cal.2d 563, 110 P.2d 1025, we held that whereas a judgment of the small claims court may operate to merge with or bar a subsequent proceeding on the same cause of action, it could not be given collateral estoppel effect with respect to common issues arising in a subsequent proceeding on a different cause of action. Our conclusion on this latter point was reached in view of the characteristics of informality inherent in the small claims proceeding. ". . . (T)here are no attorneys, no pleadings and no legal rules of evidence; there are no juries, and no formal findings are made on the issues presented. At the hearings the presentation of evidence may be sharply curtailed, and the proceedings are often terminated in a short space of time. The awards-although made in accordance with substantive law-are often based on the application of common sense; and the spirit of compromise and conciliation attends the proceedings." (Id., at p. 573, 110 P.2d at P. 1030; see also Code Civ.Proc., 117.) In these circumstances, we concluded, a judgment in such an action should not preclude the relitigation of issues decided therein in the context of a subsequent proceeding on a different cause of action. (See also Rest. 2d, Judgments (Tent. Draft No. 4) 68.1, subd. (c), reporter's notes, pp. 44-45.)