Haftman Estate

30 Pa. D. & C.2d 4, 1962 Pa. Dist. & Cnty. Dec. LEXIS 41
CourtPennsylvania Orphans' Court, Washington County
DecidedApril 2, 1962
Docketno. 239 of 1961
StatusPublished

This text of 30 Pa. D. & C.2d 4 (Haftman Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Washington County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Haftman Estate, 30 Pa. D. & C.2d 4, 1962 Pa. Dist. & Cnty. Dec. LEXIS 41 (Pa. Super. Ct. 1962).

Opinion

Marino, P. J.,

This is the claim of Henry G. Haftman, a son of testator, for reimbursement for sums expended by him for funeral expenses and cost of tombstone for decedent.

The claim in its entirety is opposed by Mrs. Delores Cherocki, the accountant, a daughter of decedent, as well as by all the other children. It is the contention of accountant and the other children that claimant was the beneficiary of certain life insurance policies on decedent’s life, and that it was decedent’s intention that the proceeds of such policies should be applied in payment of his burial expenses.

Testimony relating to the claim was submitted at.a hearing thereon. From the testimony so adduced and other competent evidence in the case, the court finds that Henry G. Haftman did pay the sum of $1183.73 to John B. Greenlee Funeral Home, covering the cost of decedent’s burial expenses, and that he also paid the sum of $415 to James Quinet for cost of a tombstone for decedent’s grave, making a total expenditure of $1598.73; also, that said Henry G. Haftman did receive the sum of $350 from the United Mine Workers Welfare Fund and the sum of $255 from the Social [6]*6Security Administration, toward expenses of decedent’s funeral, or a total credit of $605.

Claimant was the designated beneficiary of a life insurance policy on decedent’s life in the Metropolitan Life Insurance Company for $530 and a similar policy in the Constitution Life Insurance Company for $1,000. He collected the full proceeds of both policies. The beneficiary on said policies was originally the wife of decedent but she had died more than a year previously, and decedent shortly thereafter designated his eldest son, claimant herein, as beneficiary.

The objectors advance several contentions to bolster their view that it was decedent’s expressed desire that the proceeds of the policies should be applied in payment of his burial expenses. They rely largely upon loose declarations purportedly made by claimant to the effect that he intended to use said proceeds to pay decedent’s funeral expenses and the cost of a monument. Reference will be made to such declarations as have any true significance in connection with the separate subject headings under which the conceptions of objectors will be discussed.

Equitable Election

Accountant maintains that the facts here presented require that the equitable doctrine of election should operate. Mr. Bispham in his Principles of Equity, sec. 295, p. 497, 10th ed., defines this doctrine thus: It is “. . . a choice which a party is compelled to make between the acceptance of a benefit under a written instrument, and the retention of some property already his own, which is attempted to be disposed of, in favor of a third party, by virtue of the same paper.” This principle of election was cited with approval in Vassilakis v. Vassilakis, 371 Pa. 268, 273.

In Sharar’s Estate, 136 Pa. Superior Ct. 478, 484, the equitable principle of election was applied, the court stating, page 484:

[7]*7“If appellant insists on retaining the proceeds of the policy she should be required to make compensation to appellee from the assets of the estate, and she can receive no benefit under the will until appellee has realized an amount equal to the proceeds of the policy from the assets of testator’s estate.”

In Tompkins v. Merriman, 155 Pa. 440, 446, it is stated:

“The doctrine that one who accepts a benefit under a will is estopped from asserting a claim repugnant to its provisions is founded on equitable considerations, and has been recognized and applied in this state in many cases, beginning with Stump and Others v. Findlay and Others, 2 Rawle, 168; and extending to Zimmerman v. Lebo, 151 Pa. 345, and Cumming’s Appeal, 153 Pa. 397.” (Italics supplied.) See also Forsythe’s Estate, 81 Pa. Superior Ct. 347, 349; Cox v. Rogers, 77 Pa. 160; Cooley v. Houston, 229 Pa. 495; Hickman’s Estate, 308 Pa. 230, 235.

It will be observed that in the f oregoing cases, claimant was asserting a right or privilege contrary to the provisions of the will, or repugnant to it. In the Vassilakis ease, testator directed that his “life insurance money” be divided between two persons, one of whom was the designated insurance beneficiary, who collected the insurance proceeds and refused to account for same. In the Sharar case, the will provided that the proceeds of the life insurance policy “must be used to pay all funeral expenses”, thus evincing a clear intent on the part of testator to consider the insurance proceeds a part of his estate. In Tompkins v. Merriman, supra, the court refused to apply the doctrine for exactly the same reason, the will not showing the intention of testator to treat the disputed property as his own and dispose of it as a part of his testamentary scheme.

[8]*8Where is the repugnancy in the case at bar? None can be cited. Nowhere in the will do we find any allusion to the insurance proceeds. Nowhere do we find directions for payment of burial expenses from same. The will is completely silent on the matter of funeral expenses and makes no provision whatsoever for payment of such. It follows that they are payable from the general assets of the estate. It is evident, therefore, that this case is not one in which the doctrine of equitable election can be successfully invoked.

Promissory Estoppel

Accountant alternatively maintains that claimant cannot succeed because, in consideration of all the facts and circumstances of the case, he should be estopped from making any claim on account of the application of the doctrine of promissory estoppel. The principle is well established in the law. The terminology now employed to describe it, to wit, promissory estoppel, is of rather recent origin, but the principle itself goes back more than 200 years. See Kellogg/ J., dissenting opinion, Allegheny College v. National Chautauqua County Bank, 246 N. Y. 369, 381. It is now formulated in the Restatement of the Law of Contracts, §90, as follows:

“A promise which the promisor should reasonably expect to induce action or forbearance of a definite and substantial character on the part of the promisee and which does induce such action or forbearance is binding if injustice can be avoided only by enforcement of the promise.”

In Fried v. Fisher, 328 Pa. 497, 501, where the principle was invoked, Mr. Justice Stern said:

“In recent years there has been adopted the phrase ‘promissory estoppel,’ and this nomenclature is well chosen as indicating that the basis of the doctrine is not so much one of contract, with a substitute for eon[9]*9sideration, as an application of the general principle of estoppel to certain situations.”

However promissory estoppel has been characterized as a “species of consideration” by the eminent authority, Learned Hand, J., in Porter v. Commissioner of Internal Revenue, 60 F. 2d 673, 675; and as a “substitute for consideration or an exception to its ordinary requirements” by the equally famous Cardozo, C. J., in Allegheny College v. National Chautauqua County Bank, supra.

In Pennsylvania, the doctrine has been applied under various forms. A frequent application has been to cases in which a person announces his intention of abandoning an existing right, or of performing some act or duty not imposed by law, thereby inducing another, relying thereon, to some action or forbearance.

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Related

Vassilakis v. Vassilakis
89 A.2d 789 (Supreme Court of Pennsylvania, 1952)
Porter v. Commissioner of Internal Revenue
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Bair v. Snyder County State Bank
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Stelmack v. Glen Alden Coal Co.
14 A.2d 127 (Supreme Court of Pennsylvania, 1940)
Hickman's Estate
162 A. 168 (Supreme Court of Pennsylvania, 1932)
Gray v. Leibert
53 A.2d 132 (Supreme Court of Pennsylvania, 1947)
Broida v. Travelers Insurance
175 A. 492 (Supreme Court of Pennsylvania, 1934)
Fried v. Fisher
196 A. 39 (Supreme Court of Pennsylvania, 1937)
Gates v. Gates
44 A.2d 773 (Superior Court of Pennsylvania, 1945)
Sharar's Estate
7 A.2d 506 (Superior Court of Pennsylvania, 1939)
Volkwein v. Volkwein, Exr.
20 A.2d 81 (Superior Court of Pennsylvania, 1941)
O'hara's Estate
180 A. 86 (Superior Court of Pennsylvania, 1935)
Forsythe's Estate
81 Pa. Super. 347 (Superior Court of Pennsylvania, 1923)
France's Estate
75 Pa. 220 (Supreme Court of Pennsylvania, 1874)
Cox v. Rogers
77 Pa. 160 (Supreme Court of Pennsylvania, 1874)

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Bluebook (online)
30 Pa. D. & C.2d 4, 1962 Pa. Dist. & Cnty. Dec. LEXIS 41, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haftman-estate-paorphctwashin-1962.