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El blog de Maria

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Legal tip 1339. NEW! WON CASE in FIRST INSTANCE COURT AGAINST PASTOR SELECTED VILLAS INTERNATIONAL WITH JOINT LIABILITY OF CAIXABANK
Wednesday, November 11, 2015 @ 1:34 PM

WON CASE in FIRST INSTANCE COURT AGAINST PASTOR SELECTED VILLAS INTERNATIONAL WITH JOINT LIABILITY OF CAIXABANK

We were pleased to inform our clients today that we had won their case against Pastor Selected Villas International & Caixabank in the First Instance Court.  The clients did not receive an individual Guarantee from the developer, Pastor Selected Villas International or from the Bank to which their off-plan deposit was paid, CAIXABANK (formerly LA CAIXA).


Re: YOUR CASE AGAINST PASTOR SELECTED VILLAS INTERNATIONAL S.L. & CAIXABANK S.A.
PO: xxx/2013

Please find attached the Sentence from the First Instance Court No.4 in Orihuela.

Your case against PASTOR SELECTED VILLAS INTERNATIONAL S.L. & CAIXABANK S.A. has been won.

The final paragraphs of the First Instance Sentence delivered on 27 October 2015 and notified on 2 November 2015 state:



“That estimating the Lawsuit filed on behalf of xxxxxx xxxxxx & xxxxxx xxxxxx against the entity PASTOR SELECTED VILLAS INTERNATIONAL S.L. & against the entity CAIXABANK S.A. with the following pronouncements:

1. Must declare the cancellation of the Purchase Contract signed between the parties on 5 May 2006, document 1 of the Lawsuit, I must condemn the entity PASTOR SELECTED VILLAS INTERNATIONAL S.L. to refund the sum of xxx,xxx euros.

2. I must declare the legal responsibility of the entity CAIXABANK S.A. as provided in Article 1.2 of LEY 57/1968, therefore, I condemn and order the defendant Bank to pay the sum of xxx,xxx euros.

3. The amounts indicated accrue legal interest from the date of delivery or, where applicable, from the date of the deposits in the current account of CAIXABANK S.A.

4.  The costs of the Lawsuit directed against PASTOR SELECTED VILLAS INTERNATIONAL S.L. are imposed on that entity.  Without express imposition of legal costs arising from the Lawsuit directed against CAIXABANK S.A”




So your purchase contract is cancelled and PASTOR SELECTED VILLAS INTERNATIONAL S.L. is sentenced to refund the amount of xxx,xxx euros plus legal interest from the date you paid the amounts until the date of full payment to the Court.

CAIXABANK S.A. is jointly & severally liable to refund the amount of xxx,xxx euros (this being the actual amount proved to be paid into the Caixabank account) plus legal interest from the date the amounts were paid into the Caixabank account until the date of full payment to the Court. 

Legal costs for the Lawsuit against Pastor Selected Villas International S.L. are imposed on that entity.

There was no imposition of costs relating to the Lawsuit against Caixabank S.A. Therefore for this part of the procedure each party will bear its own legal costs and any common costs will be halved.

The Sentence explains the liability of CAIXABANK according to its obligations under LEY 57/1968 for the off-plan deposits paid to account opened by the developer, PASTOR SELECTED VILLAS INTERNATIONAL S.L. in CAIXABANK.


Particular points of interest stated by the Judge in the Sentence are:


Such guiding principals of consumer protection offered by LEY 57/1968 and reaffirmed by the Supreme Court states that the interpretation of the terms of the law should not be formalistic or to the detriment of the consumer.

The respondent company alleges that they have no contractual relationship with the claimants as they have not issued an individual guarantee to them.  Against this, it should be noted that we are not facing an endorsement or common strengthening of those provided for in Article 1822 of the Civil Code, but to an endorsement of a special nature regulated by the Law, LEY 57/1968 that favors an interpretation in favor of the consumer. Therefore, we should not forget that although insurance companies or financial institutions are not parties to contracts of sale, the truth is that they are not alien to their content or the performance of the obligations arising thereof, therefore they must ensure that they themselves meet the guarantees and obligations established by LEY 57/1968.

In this case we have off-plan amounts paid by the claimants and admitted to the developer’s account stipulated in the contract at Caixabank.  The witness from the Bank said it was not a special account, but an ordinary current account and due to the ordinary nature of the account the bank did not carry out any checks on the movements or amounts credited to the account. Moreover, they argue that they have no obligation to maintain such control.

The truth is that the bank opened an account for the developer in which the amounts paid by the buyers (here plaintiffs) to acquire their homes was paid and the witness has not convincingly explained to the Court what became of the amounts paid into that account.

But the truth is that the promoter opened an account to receive the amounts advanced by the purchasers and there then emerged for the bank a legal duty to ensure that those amounts were guaranteed by a certificate of insurance or a bank guarantee.  It is due to the bank having breached that duty that its legal liability is created.

However, in this case the responsibility of the Bank can only be extended to the amounts that were actually entered into the developers account and not the rest of amounts that were not paid into the account of this entity.

It should be noted that Article 1 of Law 57/1968 in its desire to protect purchasers of off-plan housing, also involves financial institutions in which the accounts are opened, establishing an obligation to them, which is none other than to demand "under its responsibility, the Guarantees referred to in the previous condition”. That is, to require, under its responsibility, that the developer has guaranteed the repayment of the amounts paid in advance (I understand that is the amounts paid to the accounts opened by the developer in this entity). This does not mean that it is the receiving bank that must issue the Guarantees, as the guarantor may be another entity.  But the term under its responsibility, is interpreted in the sense of making it responsible for damages arising to buyers to whom the security has not been provided, since by this failure, the consumers could not obtain reimbursement of the amounts paid in advance in the event of breach of contract by the developer.

In other words, the bank should not allow the opening of special accounts and allowing deposits from buyers in such accounts, without first making sure that the promoter has assumed a legal obligation to ensure the return of the amounts paid on account, and if it fails in this legal duty, the Bank is liable for the damages that such a breach creates to the buyers who cannot obtain the repayment of their advance payments.

In this case it is clear that the bank was well aware of the business in which the developer was engaged and that the income to the account by the plaintiffs was for the purchase of an off-plan property, so we are declaring that we are facing special accounts, not by the title given by both parties, but due to the origin and the destination of the funds in the account.  The fact that the account was titled as ordinary and not Special cannot be attributed to the plaintiffs.  Therefore, the Bank is not unrelated to the content of the purchase contracts and, therefore, in compliance with the obligations arising thereof, it must ensure that these are met with the guarantees established by LEY 57/1968.

Finally in relation to the alleged time limitation to bring the action, I understand that the time limit under Article 1968 of the Civil Code does not apply as it is an assumption of liability derived from Article. 1.2 of LEY 57/1968, which results in the application of the general limitation period of Article 1964 of the Civil Code.

Regarding the payment of default interest it is appropriate to order the defendants to pay the legal interest on the amounts claimed and such interest shall be computed from date the buyers paid to the account of the developer”

The river Segura, acrossing Orihuela, Alicante, East of Spain



Like 1




9 Comments


ads said:
Wednesday, November 11, 2015 @ 11:17 PM

Thank you for the update Maria and good news at first instance level.
Did the judge however provide any explanation/clarity as to why relevant costs were not also imposed on CaixaBank since they were jointly liable? Why should the innocent party be made liable to meet their share of these costs when the Bank was found to be jointly and severally liable?


mariadecastro said:
Thursday, November 12, 2015 @ 11:42 AM

Anne:

Appeal Court says it is still a matter under controversy ( it is true there is no still Case Law by the Supreme Court) and, therefore the judge is applying a provision of our Civil Procedure Act by which they cannot impose costs to losing part in case of matters which are still under judicial controversy.




ads said:
Thursday, November 12, 2015 @ 1:42 PM

Thank you Maria. So judicial moral authority does not come into the equation in the interim lengthy periods prior to Supreme Court rulings?


mariadecastro said:
Thursday, November 12, 2015 @ 1:56 PM

I take your point ads. I would impose costs if I were that judge!


Keith110 said:
Thursday, November 12, 2015 @ 4:02 PM

Ads

With regards to costs not being imposed on the bank the Judge said:

“With regards to the request for costs of the lawsuit to be imposed on CAIXABANK, even though the lawsuit has been substantially estimated in its principal claim, there is a more or less uniform criteria in the courts of this city and in the Provincial Court of Alicante to understand that the question submitted for prosecution has resulted in contradictory jurisprudence, of course comparable to doubt the existence of the right, so I plead the authority contained in Article 394 of the LEC not to impose the costs in this case. Also, it is a partial estimate of the claim directed against the financial institution, although the claim for repayment has been upheld, it is limited to the actual amounts paid in the current account with that entity”

The developer was sentenced to pay the full amount of the off-plan deposit including a very small amount paid to the developer as reservation deposit. The Bank was sentenced to pay only the amounts that could be identified as being paid to the bank account of the developer.

In this case the off-plan deposit was substantial. The developer was sentenced to pay 100% of the deposit and the bank was sentenced to pay around 99% of the deposit.

It is for that reason that the Judge called it a 'partial estimation' of the lawsuit.

The client has instructed us to appeal the non-imposition of costs on the bank.




ads said:
Thursday, November 12, 2015 @ 6:15 PM

Thank you Keith, and good luck with the ongoing appeal for non imposition of costs. I wonder if this legal aspect will also have to go to the Supreme Court if the appeal judge does not rule in favour of the claimant?

Can I ask, following this legal logic through, in a case where canx of contract has already been won at appeal level many years prior (with ruling in favour of the claimant against the developer with award of all costs and interest won at that stage against the developer), but subsequent claim against the Generic Bank became necessary due to developer insolvency, (i.e. failure to enforce the appeal ruling), should the imposition of all associated costs now be awarded against the Generic Bank, with interest backdated to the date monies were paid to all identified developer account(s)?
Should this scenario be considered as a whole entity (i.e. include all identified developer accounts associated with the deposit of monies), and not be fragmented or considered "partial estimate" as above?
Many thanks.


mariadecastro said:
Friday, November 13, 2015 @ 2:21 PM

Case against the Bank is fully independent from first one against the developer. So all the logic of the Judge and consequences of a win or a lost, need to be within this framework


ads said:
Friday, November 13, 2015 @ 7:39 PM

Thank you Maria.

How can a case against the Bank be deemed fully independent from the developer lawsuit when the costs that were incurred to gain cancellation of contract (required as proof prior to proceeding with a Bank claim following developer insolvency all those years ago) arose as a direct consequence of the Bank having breached its duty and legal liablity to provide a BG and ensure that monies were kept secure from the outset?

This becomes doubly significant if costs are also not imposed on the Bank from the subsequent action to recognise the Bank's liablilities!!

This legal logic appears to be failing to make Banks FULLY accountable for their negligence.



mariadecastro said:
Monday, November 16, 2015 @ 11:46 AM

Consequences of deposit Bank failing to ensure the existence Bank Guarantees are same as if they had guaranteed the deposits, according to Law 57/68 and its case Law.




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