Can a landlord use res judicata and collateral estoppel to bar a tenant from bringing an unlawful detainer action?

e.g., Vella v. Hudgins (1977) 20 Cal.3d 251, 142 Cal.Rptr. 414, 572 P.2d 28 (Vella ) [after tenant was evicted, landlord could not use res judicata and collateral estoppel to bar tenant's fraud action].) He maintains that even if his claims could have been settled in the unlawful detainer action, he signed the stipulation prepared by counsel for the lessors prior to trial and never had an opportunity to litigate the matter. He also stresses that he never had an opportunity to submit evidence at the ex parte hearing.