Commercial Credit Corp. v. Pasquarello

8 Pa. D. & C.3d 458, 1978 Pa. Dist. & Cnty. Dec. LEXIS 210
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedMarch 22, 1978
DocketNo. 1; no. 279 of 1975
StatusPublished

This text of 8 Pa. D. & C.3d 458 (Commercial Credit Corp. v. Pasquarello) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commercial Credit Corp. v. Pasquarello, 8 Pa. D. & C.3d 458, 1978 Pa. Dist. & Cnty. Dec. LEXIS 210 (Pa. Super. Ct. 1978).

Opinion

HENDERSON, P.J.,

— Preliminary objections have been filed in the nature of a demurrer, a motion for a more specific pleading and a motion to strike the complaint in assumpsit filed on May 5, 1975. The complaint alleges that on February 26, 1969, plaintiff loaned defendants $1,882.50 under a promissory note and as security for this loan received a secured interest in a 1966 Chevrolet automobile. Defendants defaulted in their payments after July of 1969 and in the fall of that year the automobile was repossessed by plaintiff and sold in accordance with the provisions of the Pennsylvania Motor Vehicle Sales Finance Act of June 28, 1947, P.L. 1110, 69 P.S. §601. The money received upon the sale and a finance refund [460]*460were credited to defendants’ account, leaving an outstanding balance of $883.37.

Defendants demurred, claiming that this action is barred by the statute of hmitations. Their motion for a more specific pleading requests that plaintiff be required to attach to the complaint the return receipt from the certified letter which was sent to defendants in 1969 giving them final notice of repossession as required by the Motor Vehicle Sales Finance Act. Finally, in their motion to strike defendants contend that the verification to the complaint is defective since the expiration date of the commission of the notary before whom the verification was sworn is not designated.

As is readily apparent, defendants’ primary objection is based upon the statute of hmitations. Their argument on this point is that the four-year statute of hmitations found in the Uniform Commercial Code of April 6, 1953, P.L. 3, as amended, 12A P.S. §2-725, apphes to this action rather than the six-year statute of hmitations contained in the Act of March 27, 1713, 1 Sm. L. 76, sec. 1, 12 P.S. §31. However, before we can delve into the merits of this argument, we must first resolve a rather difficult procedural question of whether this defense can be raised on preliminary objections.

Under Pa.R.C.P. 1017(b)(4) only a non-waivable statute of hmitations or frauds which bars or destroys the right of action and the applicability of which appears on the face of the complaint may be raised by preliminary objections in the nature of a demurrer. But plaintiff, in his answer to the prehminary objections, did not object to defendants’ raising the statute of hmitations on preliminary objections and instead denied the merit of the objection, i.e., he argued that the six rather than the [461]*461four-yeax statute of limitations applied. Therefore, we must initially decide whether plaintiffs failure to object to defendant’s raising of the statute of limitations waives this objection or whether Pa.R.C.P. 1017(b)(4) is mandatory. If we hold that such objection is waivable we may move on to the merits of the matter but, if we find otherwise, then it must next be determined whether the four-year statute of hmitations found in the Uniform Commercial Code is waivable or non-waivable. If that statute is found non-waivable then we can decide which statute of hmitations applies under the facts of this case, but if the Uniform Commercial Code statute of hmitations is found waivable then the demurrer must be dismissed.

In grappling with the threshold question, we note that our appellate courts have not been entirely consistent in this area. Originally it was held that failure to object to prehminary objections raising the statute of hmitations acts as a waiver: Rufo v. Bastian-Blessing Co., 417 Pa. 107, 207 A. 2d 823 (1965); Lawrence County Housing Authority v. Fireman’s Fund Insurance Co., 23 Lawrence 114, 40 D. & C. 2d 597 (1966); but later the Supreme Court ruled that under the 1969 amendments to Pa.R.C.P. 1017(b) the defense of a waivable statute of hmitations or statute of frauds may be raised only by new matter and that improper prehminary objections will be dismissed even though the other party does not object that the prehminary objection was improperly pleaded: Royal Oil & Gas Corp. v. Tunnelton Mining Co., 444 Pa. 105, 282 A. 2d 384 (1971); Ziemba v. Hagerty, 436 Pa. 179, 259 A. 2d 876 (1969).

This would seem to resolve our question. How[462]*462ever, in at least two subsequent cases the appellate courts have seemingly ignored this rule and have gone on to rule on the merits. In Lamp v. Heyman, 469 Pa. 465, 366 A. 2d 882 (1976), even though defendant filed improper preliminary objections raising the statute of hmitations, additional defendant filed an answer and new matter correctly raising the statute to which plaintiff replied admitting the facts in issue. So the Supreme Court’s decision to make a determination on the merits there can be justified since the statute of hmitations was properly raised and plaintiff did have an opportunity to reply.

In Cooper v. Downingtown School District, 238 Pa. Superior Ct. 404, 357 A. 2d 619 (1976), the Superior Court, by a four-three decision, decided a statute of hmitations issue even though it was improperly raised by prehminary objections. The majority, although recognizing that the defense was improperly pleaded, justified its reaching the merits in the interests of judicial economy because the merits of the issue had been argued, briefed, and considered in the lower court, and because defendant’s right to a judgment on the pleadings was clear. But the Superior Court has recently indicated that it beheves the better rule is to strictly refuse to consider improperly raised, waivable defenses, rather than make various exceptions under the guise of judicial economy as was done in Cooper, supra: Duffee v. Judson, 251 Pa. Superior Ct. 406, 410, 380 A. 2d 843, 845, fn. 2 (1977).

We hold that the requirement of the Rules of Civil Procedure that waivable statute of hmitations and statutes of frauds be raised only in new matter is mandatory and the court must decide the propriety [463]*463of the demurrer even though plaintiff did not object to its being improperly pleaded: Royal Oil & Gas Co., supra; 2 Goodrich-Amram 2d §1017(b):11.

Under Pa.R.C.P. 1017(b)(4) a statute of limitations or statute of frauds may only be raised by a demurrer if it provides a bar against plaintiff (1) which cannot be waived by defendant, (2) which destroys the right of action of plaintiff, and (3) the applicability of which appears on the face of the complaint. If any of these three requirements is absent, then the defense may be raised only by new matter in defendant’s answer: Duffee v. Judson, supra.; 2 Goodrich-Amram 2d §1017(b):ll.

The statute of limitations in question is found at 12A P.S. §2-725 and states:

“(1) An action for breach of any contract for sale must be commenced within four years after the cause of action has accrued. By the original agreement the parties may reduce the period of limitation to not less than one year but may not extend it.
“(4) This section does not alter the law on tolling of the statute of limitations nor does it apply to causes of action which have accrued before this Act becomes effective.”

Although no Pennsylvania appellate court has ruled on whether this statute is procedural or substantive, this exact issue has been thoroughly discussed by President Judge Coffroth of the Court of Common Pleas of Somerset County in Spickler v. Lombardo (No. 1), 32 Somerset 16 (1976).

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Related

Duffee v. Judson
380 A.2d 843 (Superior Court of Pennsylvania, 1977)
Ziemba v. Hagerty
259 A.2d 876 (Supreme Court of Pennsylvania, 1969)
Lamp v. Heyman
366 A.2d 882 (Supreme Court of Pennsylvania, 1976)
Natale v. Upjohn Company
236 F. Supp. 37 (D. Delaware, 1964)
Rufo v. the Bastian-Blessing Co.
207 A.2d 823 (Supreme Court of Pennsylvania, 1965)
Royal Oil & Gas Corp. v. Tunnelton Mining Co.
282 A.2d 384 (Supreme Court of Pennsylvania, 1971)
Cooper v. Downingtown School District
357 A.2d 619 (Superior Court of Pennsylvania, 1976)

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8 Pa. D. & C.3d 458, 1978 Pa. Dist. & Cnty. Dec. LEXIS 210, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commercial-credit-corp-v-pasquarello-pactcompllawren-1978.