Ríos Méndez v. Banco Popular de Puerto Rico

81 P.R. 368
CourtSupreme Court of Puerto Rico
DecidedMay 27, 1959
DocketNo. 11461
StatusPublished

This text of 81 P.R. 368 (Ríos Méndez v. Banco Popular de Puerto Rico) 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
Ríos Méndez v. Banco Popular de Puerto Rico, 81 P.R. 368 (prsupreme 1959).

Opinions

Mr. Justice Saldaña

delivered the opinion of the Court.

The fundamental question raised in this appeal, in brief and precise terms, is as follows: When does the limitation period of the subsidiary action of damages arising from the nullity of a mortgage foreclosure begin to run? Bearing in mind the nature of such action and the provisions of § § 1864 and 1869 of the Civil Code (1930 ed.), 31 L.P.R.A. § § 5294 and 5299, it seems unquestionable that the limitation period begins to run from the moment the marshal, in representation of the debtor, adjudicates the mortgaged property to the purchaser after the sale and the bidding have taken place and the purchase money is paid. It is necessary to consider this adjudication as a sort of sale, for it produces a conveyance for a price, in which, by operation of law, the owner’s consent is substituted by the act of a public officer. The properties are “auctioned” and “sold” at that instance and, if the purchaser so requests, he would also be immediately placed in possession thereof. 32 L.P.R.A. § 1142. Cf. Lloréns v. Arbona, 61 P.R.R. 270 (1943). In other words, the sale takes place by the mere adjudication, even though thereafter it be set up in a public deed which serves as ownership title for the purposes of its registration in the registry. Thus, if the foreclosure proceeding is null, the adjudication results in the deprivation of the property, it impairs the right of the debtor which may be revendicated immediately, and there arises the corresponding action to accomplish this, either through revendication with return of the fruits, as long as the properties have not passed into the hands of a third-party mortgagee, or through an equiva[372]*372lent or subsidiary action for damages when it is impossible to obtain the specific return of the properties with their fruits. And since there is no special provision to the contrary, the limitation period of the action of the aggrieved debtor should be counted from the day in which his right of action undoubtedly accrues. Section 1869 of the Civil Code (1930 ed.), 31 L.P.R.A. § 5299.

In the case at bar, the alleged nullity of the summary foreclosure proceeding instituted by the Banco Popular de Puerto Rico was based on the fact that the creditor collected default interest which were not secured by mortgage. Although the defendant in its original answer objected to the nullity, it thereafter admitted that the summary proceeding was void and that the property had passed into the hands of a third-party mortgagee, relying exclusively on its defense that the action for damages had prescribed. The evidence heard at the corresponding hearing before the lower court showed that the initial petition of the foreclosure proceeding was filed on March 15, 1934; that process was served on the debtor by the marshal on March 20, 1934; that the mortgaged properties were auctioned and awarded to the creditor Banco Popular de Puerto Rico on June 26, 1934; that on June 30, 1934, the deed of award at judicial sale was executed by the marshal before Notary Public Damián Monserrat y Suro in favor of Banco Popular; and that the real property was sold thereafter by the said Banco to Trinidad Soler by public deed executed on November 16, 1934. The Superior Court held as a question of law: first, that the mortgage foreclosure proceeding instituted by the Banco was null and void, according to the defendant’s admission; second, that since the property passed into the hands of a third-party mortgagee, as admitted by the defendant, the action brought by the debtor, based on the nullity of the summary proceeding, was not an action of revendication of the real property and return of the fruits [373]*373thereof, but rather the equivalent or subsidiary action for damages against the foreclosing creditor; third, that such subsidiary action for damages, brought by the plaintiff on June 20, 1949, is an ex contractu action which prescribes within 15 years; and, fourth, that the prescription period of such action begins to run from the date demand for payment is made by the marshal. Based on the foregoing conclusions, the lower court held that the action to recover the damages resulting from the nullity of the mortgage foreclosure had prescribed, and rendered judgment dismissing the complaint. The plaintiff alleges before this Court that the Superior Court erred in holding that her action had prescribed. In our opinion, she is right: the action was brought before the expiration of 15 years counted as of the sale and adjudication of the mortgaged properties, that is, as of June 26, 1934, and the prescriptive period should be counted as of that date and not from the service of process by the marshal.

We must first explain the nature of the action herein which is based on the nullity of the summary proceeding. As already pointed out, it is not an action of revendication of the real property but the equivalent or subsidiary action for damages against the foreclosing creditor. This action is based on art. 38 of the Mortgage Law (30 L.P.R.A. § 63) and art. 169 of the Regulations for its Execution (30 L.P.R.A. § 1090). The first of those articles in its pertinent part provides that “ . . . In any case in which the resolutory or rescissory action can not be brought against a third person in accordance with the provisions of this section the proper personal action may be brought for the recovery of damages from the person who may have caused them” (Italics ours.) The second article, namely, art. 169 of the Regulations, provides in its pertinent part: “. . . The [initial] petition referred to in this section, which shall always be authorized by the signature [374]*374of an attorney at law, shall enumerate the facts and the legal reasons supporting the correctness, the subsistence and the demandability of the claim and the jurisdiction of the 'Court; it shall specifically state the exact amounts collected '■by way of interest or on account of the principal of the 'debt, stating also the net amount of the claim which, by the mere act of instituting- the proceedings the creditor will contract, assuming liability for any loss or damage the debtor or interested third persons may suffer through malice or negligence in not making a true statement of facts and ■of the circumstances which the judge must take into consideration in authorizing the institution of the proceedings ■and continuing them." (Italics ours.) It is well to point •out that the Spanish foreclosure trial (art. 1429 et seq. of the Law of Civil Procedure) requires “the protest of effecting legitimate payments” (art. 1439). As pointed out by De la Plaza in II — 1 Derecho Procesal Civil Español 1412-13 (3d ed. 1955), this ritual requirement is actually a mere historical survival. Cf. 5 Manresa, Comentarios a la Ley de Enjuiciamiento Civil 467 (3d ed. 1910). Therefore, the sole purpose of the liability provision of art. 169 of the Mortgage Regulations “. . . which, by the mere act of instituting the proceedings the creditor will contract . . . , ” was to relieve the latter from making the protest required by the Spanish procedural law in the petition of the ordinary foreclosure proceeding. See González Alegre, Los Procedi-mientos Judiciales de la Ley Hipotecaria 93 (2d ed. 1955). In our law, that provision no longer plays any role, since the requirement of protest of effecting legitimate payments and also the foreclosure proceeding of the Spanish civil procedure have disappeared.

In view of the privileged position of the foreclosing creditor in the mortgage action, the precepts contained in arts.

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81 P.R. 368, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rios-mendez-v-banco-popular-de-puerto-rico-prsupreme-1959.