Reyburn's Estate

43 Pa. D. & C. 85, 1942 Pa. Dist. & Cnty. Dec. LEXIS 245
CourtPennsylvania Orphans' Court, Philadelphia County
DecidedJanuary 16, 1942
Docketno. 536
StatusPublished
Cited by3 cases

This text of 43 Pa. D. & C. 85 (Reyburn's Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reyburn's Estate, 43 Pa. D. & C. 85, 1942 Pa. Dist. & Cnty. Dec. LEXIS 245 (Pa. Super. Ct. 1942).

Opinion

Van Dusen, P. J.,

Testator, by his will, provided;

“. . . no investment shall be made in any mortgage except such mortgage be a first lien upon good productive property in the City of Philadelphia, and the amount so invested shall not exceed two thirds of the assessed value of the mortgaged premises.”

Certain mortgages were taken on property outside of Philadelphia and it is not questioned that the trustees must replace these investments with cash, and [87]*87that the mortgages should be then assigned to the persons contributing the cash.

Certain mortgages were on Philadelphia properties, but exceeded two thirds of the assessed value at the time the investments were made.

In some of these cases later increases in assessment, or reductions in the mortgage, brought the investment within the terms of the will. Exceptants urge that these cases are within section 230 (/) of the A. L. I. Restatement of the Law of Trusts as follows:

“Where the trustee is under a duty to dispose of trust property because it is not a proper trust investment, but before the trustee disposes of it it becomes a proper trust investment, the trustee is no longer under a duty to dispose of it, since it would be absurd to require the trustee to sell property which he might properly immediately repurchase.”

As to the other mortgages, it is argued that the trustees are liable only for the excess of mortgage investment over two thirds of the assessed value, and ex-ceptants cite section 229(6) of the Restatement of the Law of Trusts as follows:

“If it is otherwise proper for the trustee to lend trust money on a mortgage upon real property, but he lends more than the proper proportion of its value, he is liable to the beneficiary for the loss of the excess.” Nevertheless, the auditing judge surcharged in the amount of the whole investment in both cases.

The argument of exceptants overlooks the consideration that these mortgages of both classes were improper investments from the beginning. The error is not in quantity only, but also in quality. One of the elements in the quality of a mortgage is that of quantity; i. e., what is the margin of value of the property above the amount loaned. Prudent mortgage investment requires a margin for fluctuation of value and marketability of the property — and quite as important —a substantial investment in the property by the [88]*88owner from the beginning so as to retain his interest, and induce him to strive to pay off the mortgage. The ideal termination of a mortgage investment is not foreclosure and resale of the property, but payment by the owner. A mortgage for 100 percent of the value would be imprudent, partly because it would leave the owner no such interest. A margin of one third gives more incentive than a margin of one fourth, and a too small margin affects the whole mortgage.

The assessment of real estate is the yardstick bjwhich municipal taxes are measured. Ordinarily, it is to the advantage of the mortgagor, as well as to the mortgagee, to have the assessments kept as low as possible, in order to reduce the carrying charges of the property. The extent of the tax burden is one of the incidents which must be considered in determining the safety of the mortgage. If we were to accept the trustees’ contention with respect to those mortgages where the assessments were subsequently increased, we would condone an anomalous situation created by the trustees’ neglect. In such a situation the trustees would be benefited by a rise in the assessments, since they would be relieved of their liability for surcharge, even though the rise in the tax burden might impair the security of the mortgage investment held by the trust estate.

Furthermore, even if the trustees’ contention were correct, it would not be enough merely to show that the assessments had been increased or the mortgage loans reduced. The burden would be upon them, even under their own theory, to show by affirmative evidence that at the time in question the mortgage loans were safe, sound, and proper investments. No such testimony appears in this record.

Our usual method of handling a surcharge for an improper investment, which is that adopted by the auditing judge, is to surcharge the whole amount of the investment and to allot the improper investment [89]*89to the trustees who pay the surcharge. This is the result of the right of election by the beneficiary to accept or reject an improper investment (see A. L. I. Restatement of the Law of Trusts, §210). This method also has the advantage of determining the amount of the loss automatically upon the basis of actual realized values instead of estimated values. The paragraph quoted from section 229(6) of the Restatement above overlooks the right of election. It also overlooks the consideration that lending on too small a margin taints the whole loan.

It was said in argument that one mortgage — that on 5201 Arlington Street — has been liquidated by sale of the foreclosed property. If this is correct, the surcharge should be limited to the actual loss. The necessary facts may be stated in the schedule of distribution.

Exceptions nos. 1, 2, 3, 9, and 10 are dismissed and the other exceptions are dismissed so far as they cover the same points.

We are informed by counsel that the corporate trustee assumes sole responsibility for the mortgage on 6123 Locust Street, which was made before the individual trustee assumed office. This assumption, however, is subject to the argument against any liability, first, on the ground that the error in investment is cured by the later increase in assessment. As stated above, this objection is not well taken. Further, the corporate trustee submits that this mortgage appeared in a prior account, which was duly confirmed. Such confirmation is conclusive: Elkins’ Estate, 325 Pa. 373; and the exceptions of both the individual and the corporate trustees are sustained so far as to lift the surcharge with respect to this item.

The trustees are a trust company and an individual. The surcharge is placed on both, and it is not denied that as between the beneficiary and the trustees both trustees are liable. The individual trustee, however, seeks to have the question of contribution between him[90]*90self and the corporate trustee determined at this time. We think that this court has jurisdiction to determine this question of contribution, on the general principle that a court of equity, having jurisdiction of a principal cause of action, will settle all the collateral issues which grow out, of it. This is particularly appropriate in determining such questions as contribution and order of liability.

All investments were initiated by the trust company. The individual trustee says that he knew nothing about the terms of the will, and nothing about the value of the properties on which mortgages were taken, or their assessed values or their locations; that his approval of the investments was given on the supposition that the trust company had investigated the facts, and that the investments were in all respects proper.

If the trust company had misstated material facts relating to the investment, as for example the amount of the assessment, or if the trust company had peculiar knowledge with regard to a mortgage which was not communicated to the individual trustee, it would appear that the trust company was primarily liable as between the trustees.

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43 Pa. D. & C. 85, 1942 Pa. Dist. & Cnty. Dec. LEXIS 245, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reyburns-estate-paorphctphilad-1942.