In re: Builders Holding Co., Corp., Noreen Wiscovitch Rentas, Trustee for the Estate of Builders Holdings Co., Corp. v. Oriental Bank and the Puerto Rico Financing Authority; Mapfre Praico Insurance Company and Endurance Assurance v. Oriental Bank, Builders Holding Co., Corp., and the Puerto Rico Financing Authority; Oriental Bank v. Builders Holding Co., and Mapfre Praico Insurance Company and Endurance Assurance

CourtUnited States Bankruptcy Court, D. Puerto Rico
DecidedMarch 16, 2026
Docket17-00012
StatusUnknown

This text of In re: Builders Holding Co., Corp., Noreen Wiscovitch Rentas, Trustee for the Estate of Builders Holdings Co., Corp. v. Oriental Bank and the Puerto Rico Financing Authority; Mapfre Praico Insurance Company and Endurance Assurance v. Oriental Bank, Builders Holding Co., Corp., and the Puerto Rico Financing Authority; Oriental Bank v. Builders Holding Co., and Mapfre Praico Insurance Company and Endurance Assurance (In re: Builders Holding Co., Corp., Noreen Wiscovitch Rentas, Trustee for the Estate of Builders Holdings Co., Corp. v. Oriental Bank and the Puerto Rico Financing Authority; Mapfre Praico Insurance Company and Endurance Assurance v. Oriental Bank, Builders Holding Co., Corp., and the Puerto Rico Financing Authority; Oriental Bank v. Builders Holding Co., and Mapfre Praico Insurance Company and Endurance Assurance) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Builders Holding Co., Corp., Noreen Wiscovitch Rentas, Trustee for the Estate of Builders Holdings Co., Corp. v. Oriental Bank and the Puerto Rico Financing Authority; Mapfre Praico Insurance Company and Endurance Assurance v. Oriental Bank, Builders Holding Co., Corp., and the Puerto Rico Financing Authority; Oriental Bank v. Builders Holding Co., and Mapfre Praico Insurance Company and Endurance Assurance, (prb 2026).

Opinion

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF PUERTO RICO

IN RE: CASE NO. 16-06643 (EAG)

BUILDERS HOLDING., CORP., Chapter 7

DEBTOR.

NOREEN WISCOVITCH RENTAS, TRUSTEE FOR THE ESTATE OF BUILDERS ADV. PROCEEDING NO. 17-00012 HOLDINGS CO., CORP.,

PLAINTIFF,

v.

ORIENTAL BANK and the PUERTO RICO FINANCING AUTHORITY

DEFENDANTS.

MAPFRE PRAICO INSURANCE COMPANY AND ENDURANCE ASSURANCE

INTERVENOR-PLAINTIFF,

ORIENTAL BANK, BUILDERS HOLDING CO., CORP., and the PUERTO RICO FINANCING AUTHORITY

INTERVENOR-DEFENDANTS,

ORIENTAL BANK,

COUNTER-CLAIMANT,

v. BUILDERS HOLDING CO., and MAPFRE PRAICO INSURANCE COMPANY AND ENDURANCE ASSURANCE

COUNTER-DEFENDANTS 1 Opinion and Order 2 Builders Holding Co., a general contractor, and the Puerto Rico Financing Authority entered into a contract for the construction of a project known as “Revitalización del Poblado de 3 Boquerón en el Municipio de Cabo Rojo.” Builders failed to make payments to the project’s 4 vendors. MAPFRE, the bonding company, sent a letter to the Financing Authority informing it of claims received under the bonds covering the project and that all further project payments, 5 including progress payments, retainage, or additional claim amounts, had to be sent to MAPFRE 6 and made payable jointly to Builders and MAPFRE. The Financing Authority failed to comply with MAPFRE's request and made a deposit of $537,924.18 to Builders’ account at Oriental Bank. 7 At the time of the erroneous deposit, Builders had a matured debt with Oriental on two lines of 8 credit. As a consequence, on the same day the deposit was made, Oriental applied $464,757.60 to the outstanding balance of the lines of credit. 9 Builders filed a bankruptcy petition under chapter 11 and later filed this adversary 10 proceeding against the Financing Authority and Oriental. The relevant procedural matters occurring thereafter are discussed in this court’s previous opinion and order at docket 138 and in 11 the opinion and order of the United States Court of Appeals for the First Circuit at docket 197. 12 The Court of Appeals, in its opinion, found that the bankruptcy court’s decision was based exclusively on the Puerto Rico Civil Code provisions on the payment-in-error doctrine. However, 13 neither the bankruptcy court nor the district court explained how the doctrine could be expanded 14 to the facts here, that is, where there was one level/degree of removal/separation between the payor and the receiver. In remanding the case back to this court, the Court of Appeals posed three 15 questions that were not addressed by this court: (1) whether Oriental’s set-off is senior to 16 MAPFRE’s secured interest in the same collateral; (2) whether Oriental’s set-off was a mutual debt; and (3) whether Oriental’s set-off was otherwise valid under Puerto Rico law under other 17 doctrines, such as unjust enrichment. Additionally, the Court of Appeals suggested that the 18 questions of Puerto Rico law implicated in this controversy could be certified to the Puerto Rico Supreme Court. 19 During a hearing held on August 24, 2022, the parties agreed to suspend efforts to certify 20 the matter to the Puerto Rico Supreme Court until after filing new summary judgment motions on the three questions posed by the Court of Appeals. After the filing of new summary judgment 21 motions and after a hearing held on October 30, 2024, the parties supplemented their motions. 22 For the reasons set forth below, the court determines that no material issue of fact exists, and MAPFRE is entitled to summary judgment in its favor as a matter of law. Although the court 23 centers its analysis around the three questions posed by the Court of Appeals, the change post- remand in legal strategy by the parties is also addressed in this opinion and order. 24

25 I. Jurisdiction 26 This court has jurisdiction over the subject matter and the parties pursuant to 28 U.S.C. §§ 1334 and 157(a), Local Civil Rule 83K(a), and the General Order of Referral of Title 27 11 Proceedings to the United States Bankruptcy Court for the District of Puerto Rico dated 28 29 1 July 19, 1984 (Torruella, C.J.).1 Although Oriental had argued that this is a non-core proceeding that would exist outside of bankruptcy, it consented to this court hearing the matter and entering 2 final judgment. (Adv. Dkt. No. 9, ¶14.) 3 II. Uncontested Facts 4 The following facts are uncontested pursuant to Rule 56 and Local Civil Rule 56, made 5 applicable to these proceedings by Bankruptcy Rule 7056 and Local Bankruptcy Rules 1001-1(b) and (d), as found in the record of this case and the statements of proposed uncontested facts filed 6 by the parties: 7 a. Indemnity Agreement between C.D. Builders and MAPFRE On August 5, 2010, C.D. Builders, Inc.2 executed an Agreement of Indemnity with 8 MAPFRE. C.D. Builders promised to exonerate, hold harmless, and indemnify MAPFRE for any 9 and all actual or potential loss as a consequence of the execution of bonds on its behalf. (Adv. Dkt. No. 205, Exhibit 1, Indemnity Agreement, p. 3 at ¶3.) 10 To comply with its indemnity obligations, C.D. Builders assigned to MAPFRE all rights, title, 11 and interest in all bonded contracts, including its rights to any and all sums due or which may become due under all bonded contracts. (Adv. Dkt. No. 205, Exhibit 1, Indemnity Agreement, p. 4 12 at ¶4.) 13 Paragraph 8 (“Trust Funds”) of the Indemnity Agreement states: All payments received for or on account of any CONTRACT shall be held 14 in a trust fund to assure the payment of obligations incurred or to be incurred in the 15 performance of any CONTRACT and for labor, materials, and services furnished in the prosecution of the work in any CONTRACT or any extension or modification 16 thereof. All moneys due and to become due under any CONTRACT are also trust funds, whether in the possession of PRINCIPAL, INDEMNITORS or otherwise. 17 The trust funds shall be for the benefit and payment of all obligations for which 18 SURETY may be liable under any BONDS. The trust funds shall inure to the benefit of SURETY for any liability or loss it may have or sustain under any 19 BOND, and this Agreement and declaration constitute notice of such trust. 20 (Adv. Dkt. No. 205, Exhibit 1, Indemnity Agreement, p. 5 at ¶8.) 21 b. MAPFRE’s UCC filings 22 On August 30, 2010, MAPFRE filed the Indemnity Agreement in the Department of State of Puerto Rico as a financing statement. (Adv. Dkt. No. 205, Exhibit 2, Official certification of 23 financing statements registered in the records of the Department of State.) 24

25 1 Unless otherwise indicated, all references to “Bankruptcy Code” or to specific statutory sections are to the Bankruptcy Reform Act of 1978, as amended, 11 U.S.C. §§ 101-1532. All references to “Bankruptcy Rule” are to the 26 Federal Rules of Bankruptcy Procedure, and all references to “Rule” are to the Federal Rules of Civil Procedure. All references to “Local Bankruptcy Rule” are to the Local Bankruptcy Rules of the United States Bankruptcy Court for 27 the District of Puerto Rico. And all references to “Local Civil Rule” are to the Local Rules of Civil Practice of the United States District Court for the District of Puerto Rico. 28 2 On June 29, 2016, C.D. Builders and CDC Maintenance Group, Corp. merged into the debtor, Builders Holding Co., 29 Corp. (Adv. Dkt. No. 1, ¶14.) 1 c.

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In re: Builders Holding Co., Corp., Noreen Wiscovitch Rentas, Trustee for the Estate of Builders Holdings Co., Corp. v. Oriental Bank and the Puerto Rico Financing Authority; Mapfre Praico Insurance Company and Endurance Assurance v. Oriental Bank, Builders Holding Co., Corp., and the Puerto Rico Financing Authority; Oriental Bank v. Builders Holding Co., and Mapfre Praico Insurance Company and Endurance Assurance, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-builders-holding-co-corp-noreen-wiscovitch-rentas-trustee-for-prb-2026.