Santi Galleti v. Federal Land Bank of Baltimore

48 P.R. 99
CourtSupreme Court of Puerto Rico
DecidedFebruary 15, 1935
DocketNo. 6855
StatusPublished

This text of 48 P.R. 99 (Santi Galleti v. Federal Land Bank of Baltimore) 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
Santi Galleti v. Federal Land Bank of Baltimore, 48 P.R. 99 (prsupreme 1935).

Opinion

Mr. Justice Córdova Davila

delivered the opinion of the court.

Antonio Miranda Berrios and his wife, Teresa de Jesús Rodríguez, the owners of two properties situated in Yillalha, on January 21, 1925, applied to the Federal Land Bank of Baltimore for a loan of $5,000. The hank agreed to make the loan on March 24, 1925, reducing the amount to $3,700, and accepted the said two properties as mortgage security. The borrowers informed the bank that $500 was for the construction of a dwelling house and $250 for fences, repairs, and improvements. On May 4, 1932, the defendant bank sought to enforce its credit through the summary proceeding authorized by the Mortgage Law. This proceeding was directed against Julia Garcia Reyes, who then appeared to be the owner of the properties, but it was later proved, to the satisfaction of the lower court, that said immovables belonged to Roque Santi' and Maria Garcia Reyes, and hence the prosecution of the summary foreclosure proceeding was continued against them. Both properties, one of ninety-three cuerdas and the other of four cuerdas and some hundredths of a cuerda, were awarded to the defendant bank, which took possession of the larger tract, the possession of the smaller tract remaining pending. The lower court dismissed the complaint on the merits, as it considered, among other things, that since the mortgage had been constituted prior to the date of the purchase of the property by the plaintiffs, their right to avail themselves of the homestead exemption authorized by law did not exist. The defendant bank had set up this defense and further alleged that, of the amount of [101]*101the mortgage loan, $500 had been lent by the said bank for the construction of the dwelling house now claimed by the plaintiffs, and $250 for improvements on the two mortgaged properties which answer jointly and severally for the amount of the mortgage. The lower court held that, as the purchasers had not been parties to the original application for the loan, wherein were stated the purposes for which said amounts should be expended, they were not bound with notice of that instrument.

The first error assigned relates to the dismissal of the action by the lower court on the ground that it had been shown that at the time of the execution of the mortgage the plaintiffs had not constituted their homestead. It is further urged that the court a quo erred in failing to hold that, as there was a homestead right in favor of Mr. Miranda, the former owner, who had not abandoned the same at the time of the execution of the mortgage in favor of the Federal Land Bank of Baltimore, and as he had sold and delivered the said property to the plaintiffs who were heads of family and qualified to establish, as they did establish, a. homestead on that property, such homestead was legally constituted by them to the prejudice of the mortgagee, inasmuch as such homestead right was not abandoned either by the original mortgagor or by the purchasers thereof.

The essential question to be decided in this case is whether the plaintiffs, who purchased the property, acquired it free from encumbrances or liens through the fact that the spouses who sold it had their homestead constituted therein. In other words, whether, despite the fact that the owners had sold and vacated the property and had given the plaintiffs material possession thereof, the homestead exemption that existed in favor of the original owner continued in force to the extent that it could be successfully set up against a mortgage credit duly recorded in the registry of property. In some jurisdictions, when a homestead is sold by its owner, the purchaser acquires the property subject to all valid claims [102]*102or judgments rendered against the vendor, even where they could not have been made effective on the property if the owner had remained in its enjoyment and possession. In . ther jurisdictions, however, it has been held that the exemption runs with the land, following the conveyance and protecting the property as if it continued to be the residence of the debtor. In Mississippi, in accordance with the old revised code, p. 529, sec. 281, as soon as a debtor abandoned his homestead by virtue of a sale to a third person, the property could be attached for the payment of an existing judgment against the debtor. In 1908, however, there was incorporated in the code a provision according to which, upon the sale of the property, the homestead does not answer for the1 debts contracted by its owner. In Illinois, in 1872, it was provided that when a homestead is transferred by its owner,, such conveyance shall not subject the property to any encumbrance or lien to which it would not have been subject, in the possession of its owner. In the State of Louisiana,, the exemption granted to the owner of a homestead ceases, when the property passes into other hands. In North Carolina, in 1905, a law was passed in which it was declared that when the homestead is sold and conveyed, the exemption ends and the property is subject to the payment of existing liens.

Our homestead law provides that the homestead shall be exempt from attachment, judgment, or forced sale, with the exception of taxes, the purchase price of the property, and the liability incurred for improvements made thereon. It might be that if these provisions were examined and analyzed by several courts, a uniform conclusion would not be reached. In examining the adjudicated cases it is observed that where the law exempts the homestead from a forced sale, the opinion prevails that a property which is surrendered by virtue of a sale answers for the liens existing thereon at the time of the conveyance. Smith v. Brackett, 36 Barb. (N. Y.) 571; Allen v. Cook, 26 Barb. (N. Y.) 374. It has been held, however, that where the exemption covers the judgment also, [103]*103the property is sold free from encumbrances and liens. We are perfectly aware of the differences established by certain courts, but their reasoning does not convince us. Our law does not deprive the head of the family, who can sell, of the right to encumber the property with the consent of-his spouse, and when, by making use of this right, he mortgages what belongs to him, the lien is constituted immediately, even though it is held in abeyance as long as the homestead subsists under the protection of the exemption; but when the property is sold and abandoned, the dormant lien, which constitutes a notice to everyone, acquires force and vigor and may be made effective on the property in the possession of the purchaser. The exemption from a judgment and sale on execution does not, in our opinion, prevent the general principles in which the institution of homestead was inspired from its beginning, from being applied to a mortgage lien. Abiding by those principles, it seems to us that the doctrine upheld by the Supreme Court of Louisiana is the one most acceptable in this jurisdiction.

In the case of Hebert v. Mayer, 42 La. Ann. 839, 8 So. 590, the plaintiff, owner of 160 acres of land, had his homestead set apart and secure. He sold the property, which passed into the hands of several persons and was finally repurchased by him. Then the defendant obtained a judgment against the plaintiff and proceeded to attach the property. The plaintiff obtained an injunction against Mayer, restraining him from executing the judgment. The defendant appealed, and in deciding the question raised, the Supreme Court of Louisiana said:

“Under Article 219 of the Constitution, the homestead must be owne’d bona fide by the debtor and occupied by him.

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Bluebook (online)
48 P.R. 99, Counsel Stack Legal Research, https://law.counselstack.com/opinion/santi-galleti-v-federal-land-bank-of-baltimore-prsupreme-1935.