Mulet v. Local Committee of the Unionist Party

24 P.R. 541
CourtSupreme Court of Puerto Rico
DecidedJuly 28, 1916
DocketNo. 1451
StatusPublished

This text of 24 P.R. 541 (Mulet v. Local Committee of the Unionist Party) is published on Counsel Stack Legal Research, covering Supreme Court of Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mulet v. Local Committee of the Unionist Party, 24 P.R. 541 (prsupreme 1916).

Opinion

Mu. Justice Hutchison

delivered the opinion of the court.

Defendant, appellant, during the political campaign of 1914, acting through its chairman, made arrangements with the plaintiff firm for the opening of an account and for the filling of prescriptions bearing for purposes of identification and as evidence of due authorization thereof the stamp of the official seal of the committee, and, in addition thereto, in certain specified eases, as subsequently provided by resolu: tion of said committee, notice of which was given to said plaintiff in writing, the signature of the said chairman thereof.

Various instalments were paid on the account and plaintiff, appellee, obtained judgment in the District Court of Mayagiiez against defendant, appellant, for a balance of $622.45, with interest, costs, disbursements and attorney’s fees, on account of drugs and medicines so furnished at the instance and request and upon the express promise of de[542]*542fendant, appellant, in an assumed, if not an actual, corporate ■capacity, to pay any sneli balance in full after the elections.

Plaintiff, apparently referring to the Unionist Party as well as to its local committee, alleged, among other things, that defendant is “a body politic duly organized under the laws of Porto Rico, whose representation is conferred upon its committee, which is authorized to contract debts.” The defendant committee appeared as such by its attorney and demurred to the complaint on the grounds, first, that the court had no jurisdiction over the person of the defendant political committee, and, second, that the complaint did not state facts sufficient to constitute a cause of action. It does not appear upon what theory these grounds were sought to be sustained below nor that any question of want of corporate capacity was raised or had occurred to defendant prior to the filing of its answer.

The demurrer was overruled by the court and defendant answered denying each and every allegation of the complaint, adding to its denial of the averment first above-mentioned the affirmative statement that “the defendant political committee only has authority to call political conventions, which elect the candidates who are to fill the public offices in the city of Mayagiiez,” and set out as new matter the further defence that:

“ (a) The local committee, defendant, is not recognized by any law in Porto Rico and is not incorporated in the office of the Secretary of Porto Rico in accordance with the law of corporations in force, nor in .accordance with any other law.
“(b) The defendant local committee has no legal capacity to appear in any way before the courts of, Porto Rico either as a juristic person or as a political entity, or in any other capacity.”

The only evidence introduced by defendant is a letter from the office of the Secretary of Porto Rico which reads as follows:

“San Juan, November 1, 1915. — Sir: I have the honor to acknowledge receipt of your letter of the 30th ultimo and to inform [543]*543you in reply that the Local Committee of the Unionist Party of Porto Rico in Mayagiiez is not registered in this office as a corporation or association under the Acts of March 9, 1911, governing private corporations and associations not for pecuniary profit. Respectfully, A. Siaca Pacheco, Acting Secretary of Porto Rico. — Mr. Angel A. Vazquez, Attorney and Notary, Mayagiiez, P. R.”

The record shows the following findings of fact and conclusions of law:

“It was proved by the plaintiff that in the month of July of 1914, Luis Vilella Vélez, acting as president of the local committee of the Unionist Party of Porto Rico in Mayagiiez and as such president, requested and obtained from the plaintiff firm the opening of an account for the furnishing by said plaintiff of medicines and drugs to the members of his party during the electoral campaign of that year and the plaintiff firm proved that the medicines were to be delivered to all persons who presented prescriptions or orders stamped with the seal of the defendant committee. The plaintiff firm proved also that it so delivered medicines to different persons on orders of the defendant committee to the value of $630.45 over and above the amounts paid on account. The plaintiff firm proved also that an account of $62 which the said committee had with the Successors of G-. Mulet was added to the plaintiff’s account, making a total of $692.45 and that the said account had not been paid in whole or in part.
“The defendant introduced no evidence but only objected to the admission of the account presented by the plaintiff firm on account of the fact that it did not appear in an official book of the said 'firm •and placed great reliance upon the fact that the defendant political party was not incorporated under the laws of Porto Rico or of anywhere else and therefore had no capacity to be sued.
“As to the first proposition, the court is of the opinion that there is clear proof of the existence of the account and the delivery of the merchandise by the plaintiff firm at the request and for the benefit of the defendant committee and that the latter has not paid the resulting debt. The contract entered into between Luis Vilella Vélez as president of the defendant committee (and the plaintiff) is clearly corroborated by the letter of August 15, 1915, written by Vilella Vélez as such president to Luis Mulet, managing partner of the plaintiff firm, in which mention is made of the contract for [544]*544furnishing the medicines, therefore the defendant committee cannot now repudiate an account which was created at its instance.
“As to the second contention, that the defendant committee is not incorporated in accordance with the laws of Porto Rico governing corporations not for pecuniary profit, we will say that there are two classes of corporations known as de jiore and de facto corporations and the court is of the opinion that the defendant committee is a de facto corporation.
“According to this doctrine we find in this case that there is a law in Porto Rico for the organization of associations not for pecuniary profit — Act No. 22 passed by the Legislative Assembly of Porto Rico on March 9, 1911 — and under this law a de jure corporation of the same character, class and nature as the defendant committee may be organized. As it was proved at the trial that this committee is organized with a president, a secretary and various members and that they together have acted as they would have acted as an organized corporation de jure, the court holds that it is a de facto corporation.”
“ ‘If there is a law authorizing incorporation and a company has attempted to organize under it and has acted as a corporation, it is a de facto corporation, and its de jure existence can be questioned only by the State. Cook on Corporations, 6th ed., vol. 2, p. 1805.’
“At the same page and in the note appearing at the bottom is reported the case of Independent Order v. United States, 94 Wis. 234.
“ ‘The test of a de facto corporation is this: Was there a law under which there might have been a de jure corporation of a kind, character, and class to which the organization in question apparently belongs. ’

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24 P.R. 541, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mulet-v-local-committee-of-the-unionist-party-prsupreme-1916.