Trust in Family Law & Trustee Removal Cases — Puerto Rico

2. Fideicomiso Caro Delui Representado por su Fiduciaria v. Rodriguez Beauchamp, 2012 WL 1515184 (2012)

Headline

Trust Fiduciary Holds Legal Title and May Sue Independently; Doctrine of Res Judicata Applies to Trust Personality

Court

Tribunal de Apelaciones (Court of Appeals), Panel integrado by Judges García García, Varona Méndez, and Gómez Córdova

Date

March 14, 2012

Summary of Relevant Facts

On March 24, 1968, Señor José Ramón Rodríguez Beauchamp established a marriage regime of complete separation of property. During the marriage, Rodríguez Beauchamp acted as exclusive administrator of all assets acquired during the marriage, including a trust that was constituted by Rodríguez Beauchamp through a public deed titled "Escritura Número 40, Constitución de Fideicomiso" (Public Deed No. 40, Constitution of Trust). The trust was designed to secure the future economic well-being of Rodríguez Beauchamp's spouse, Señora Caro. The trust contained twenty-six (26) shares of Aeroboutique de Puerto Rico, Inc., valued at $50,000.00 each for a total trust value of $1,300,000.00. Rodríguez Beauchamp was designated as the first trustee/administrator. Señora Caro was designated as trust fiduciary. When the marriage was dissolved or separated, Rodríguez Beauchamp was expected to be replaced as trustee by their son, Delui Beauchamp Caro. Subsequently, Señora Caro and Rodríguez Beauchamp entered into a "Private Contract for Payment Terms" (Contrato Privado de Dación en Pago) on the same date. This contract specifically documented the results of the Aeroboutique stock liquidation. The trust corpus (trust assets held in Aeroboutique shares) was liquidated at a value significantly lower than the original $1,300,000.00 valuation, resulting in a reduction to $447,644.00.

Procedural Background

On July 7, 2004, Señora Caro presented a claim for division of community property to the trial court. She alleged that a community of property existed between her and Señor Rodríguez Beauchamp and that this community included multiple movable and immovable assets. She specifically claimed that the trust should be included in the community property division and requested reimbursement for the devaluation of Aeroboutique shares held in the trust. During marriage, Rodríguez Beauchamp acted as exclusive administrator of all assets including trust management. Señora Caro later brought a claim in 2010 asserting that Rodríguez Beauchamp owed her the difference in value of the liquidated trust shares (20 shares of Aeroboutique). The trial court initially rejected the division of community property claim after determining that the trust held private property status and that Rodríguez Beauchamp's management of trust assets during marriage did not create community property interests.

Main Controversies

(1) Whether a trust constituted by a married person can hold community property or must be treated as private property; (2) Whether a trust fiduciary has independent legal standing to sue separate from beneficiary interests; (3) Whether the doctrine of res judicata (cosa juzgada) applies to trusts with separate legal personality; (4) Whether Señora Caro, in her capacity as fiduciary representing the trust, could sue for trust asset devaluation; (5) Whether the trust's legal personality provides imputed standing distinct from beneficiary status.

Position of the Parties

Señora Caro (as trust fiduciary) argued that the trust held separate legal personality and that she, as fiduciary, could independently bring suit for damages resulting from the devaluation of trust assets. She contended that prior litigation (in which the trial court adjudged the property private) did not bar a new claim for restitution of the devolved value because the prior action concerned division of community property while the current action seeks recovery for trust asset depreciation. Señor Rodríguez Beauchamp countered that Señora Caro lacked standing to bring suit because she was both fiduciary and beneficiary of a trust that constituted his private property, and that prior adjudication of the community property character (or lack thereof) of trust assets was final and binding.

Holding/Decision

The Court of Appeals held that: (1) a trust constituted separate legal personality under Puerto Rico law and may be represented by its fiduciary in judicial proceedings; (2) the fiduciary's standing to sue derives from the trust's own legal personality and fiduciary duties, not solely from beneficiary status; (3) the doctrine of res judicata applies to trusts and prevents relitigation of issues that were definitively adjudicated in prior proceedings; (4) however, impeded colateral remedy by sentencia (alternative procedural doctrine allowing collateral challenge to judgments) did not apply because the prior judgment was final and firm; (5) the fiduciary's attempt to relitigate trust asset valuation through a new damages claim was barred by res judicata principles.

Reasons for the Decision

The court analyzed the trust's legal personality under Puerto Rico law, adopting a mixed approach incorporating Anglo-Saxon trust principles while respecting Puerto Rico's civil law tradition. The court noted that while Article 852 of the Civil Code establishes that confusion of trustee and sole beneficiary character terminates a trust, this does not prevent a trust from existing as a separate juridical entity capable of being represented by a fiduciary in litigation. The court distinguished between the trust fiduciary as an individual and the trust as an entity with separate interests. Regarding standing, the court applied principles recognizing that the fiduciary holds legal title to trust assets and bears fiduciary duties to the trust itself (not merely to beneficiaries), thus possessing independent interest in defending trust assets. However, applying res judicata doctrine, the court held that when a prior judgment definitively resolved the nature of trust property (whether private or community), a subsequent action seeking recovery for asset devaluation based on the same underlying property dispute constitutes res judicata. The court emphasized that allowing the fiduciary to relitigate asset valuations under the guise of a damages action would undermine finality of judgments and encourage repetitious litigation.

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3. Triangle Cayman Asset Company v. Perez Mendoza, 2016 WL 3165884 (2016)

Headline

Original Trustee's Informal Resignation by Letter Does Not Terminate Fiduciary Status; Court Approval Required for Trustee Resignation Under Civil Code Article 861

Court

Tribunal de Apelaciones (Court of Appeals), Panel integrado by Judges Fraticelli Torres, Ortiz Flores, and Ramos Torres

Date

April 22, 2016

Summary of Relevant Facts

On October 20, 2005, the Fideicomiso Pérez Mendoza was created through a public deed. Vicente Pérez Santiago and Aracelis Mendoza Chidiak served as settlors, designating their children as beneficiaries. Oriental Bank and Trust was named as the original trustee. The deed expressly stipulated that settlors could not serve as trustees. Subsequently, Pérez Santiago, Oliveras Rodríguez, and Pellegrini Castro executed a commercial loan agreement with Eurobank for real property purchase, and the Fideicomiso Pérez Mendoza served as collateral under pledge and mortgage arrangements. On October 30, 2010, the Puerto Rico Commissioner of Financial Institutions ordered closure of Eurobank and appointed the FDIC as receiver. That same date, Oriental Bank acquired the commercial loan from Eurobank's assets. On December 21, 2011, Oriental Bank sent a certified letter with return receipt to Pérez Santiago and Mendoza Chidiak notifying them that Oriental Bank was ceasing its functions as trustee and requesting that they appoint a successor trustee within thirty (30) days. The letter was returned as "unclaimed." In November 2012, Oriental Bank filed suit for money recovery and execution of pledge/mortgage against the Fideicomiso Pérez Mendoza, Pérez Santiago, Oliveras Rodríguez, Pellegrini Castro, and the community property they comprised.

Procedural Background

Pérez Santiago requested nullification of service of process, arguing he was not an authorized agent to receive service for the trust because Oriental Bank had already resigned as trustee. Oriental Bank opposed, asserting it had properly notified settlors of resignation through the December 2011 certified letter. The trial court ruled that service was adequate under the particular circumstances. Pérez Santiago appealed. A sibling panel of the Court of Appeals issued a decision on September 30, 2014 (in case KLCE201401071) reversing the trial court and concluding that Oriental Bank's resignation was ineffective and that service of process was improper. That panel held that under Civil Code Article 861, the original trustee (not a successor trustee) must petition the trial court for approval of resignation, and that unilateral notification by letter cannot substitute for court-approved resignation. The panel further held that since the resignation was improper, neither the settlors nor the successor trustees could be presumed to have assumed trustee roles, and thus proper service could not be effectuated through Pérez Santiago. The trial court was ordered to conduct an evidentiary hearing to determine the sufficiency of reasons for resignation. However, the trial court subsequently ignored this mandate and issued a partial judgment ordering the trust to pay approximately $492,121.10 to Oriental Bank.

Main Controversies

(1) Whether an original trustee may validly resign by sending a notice letter without court approval; (2) Whether such informal resignation effectively terminates the trustee's status and fiduciary duties; (3) Whether, absent effective trustee resignation, proper service of process can be effectuated through a settlor; (4) Whether a trustee has absolute discretion to resign or whether judicial oversight is required; (5) Whether a prior appellate mandate directing an evidentiary hearing creates binding effect that trial courts must follow.

Position of the Parties

Pérez Santiago (later joined by substitute plaintiff Triangle Cayman Asset Company, which acquired Oriental Bank's claim) argued that Oriental Bank had no authority to resign unilaterally and that proper procedure required court approval. He contended that Oriental Bank remained trustee and that service through a settlor was therefore improper. Oriental Bank argued that its resignation was effective under the trust deed's clause permitting trustee resignation upon written notice to settlors, and that this contractual arrangement superseded statutory requirements.

Holding/Decision

The Court of Appeals held that: (1) the original trustee cannot resign merely by sending a notice letter to settlors; (2) Civil Code Article 861 (applicable at the time) required that an original trustee petition the trial court with jurisdiction and that the court determine the sufficiency or insufficiency of reasons for the proposed resignation; (3) Oriental Bank's December 2011 letter did not comply with statutory resignation procedures and therefore did not terminate Oriental Bank's fiduciary status; (4) consequently, the trust remained under Oriental Bank's fiduciary authority, and service of process could not properly be effectuated through a settlor; (5) the trial court erred in ignoring a prior appellate mandate ordering an evidentiary hearing and instead issuing judgment against the trust; (6) Pérez Santiago demonstrated standing and legitimation to appeal as former trustee and protector of beneficiary interests.

Reasons for the Decision

The court recognized that while Article 855 of the Civil Code permits settlors to create trusts in any form subject to law and public policy, this flexibility does not permit circumventing mandatory procedural requirements for trustee resignation. The court held that Article 861 establishes the exclusive procedure for trustee resignation: the trustee must petition the competent trial court, which must determine whether the reasons are sufficient and whether forcing the trustee to continue would be unreasonably burdensome. The court reasoned that an original trustee's fiduciary duties are irrevocable and cannot be unilaterally abandoned through informal notice. The court distinguished between original trustees (whose resignation requires court approval) and successor trustees (who may resign more readily). The court emphasized that Oriental Bank had failed to follow the proper procedure and therefore remained bound by fiduciary duties despite its express wishes to terminate the relationship. Additionally, the court held that the trial court's failure to follow the appellate mandate—ordering an evidentiary hearing before judgment—constituted an abuse of discretion that violated the principle that appellate decisions constitute binding law between the parties.

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4. Carvajal Narvaez v. Scotiabank of Puerto Rico, 2018 WL 1863663 (2018)

Headline

Trust Modification After Legislative Change Renders Prior Judgment Moot; Certiorari Discretionary Review Denied Where No Substantial Controversy Exists

Court

Tribunal de Apelaciones (Court of Appeals), Panel integrado by Judges Jiménez Velázquez, Cintrón Cintrón, and Rivera Marchand

Date

February 7, 2018

Summary of Relevant Facts

Francisco Carvajal Narváez and Agnes Dora Fuertes Alou, serving as settlors and trustees of the Fideicomiso Hispamer, filed a suit against Scotiabank of Puerto Rico and five individuals (Juan B. Aponte Vázquez, Enrique Fierres González, Manuel de J. González Hernández, Ángel L. Rivera Ortiz, and Fernando Torrent Mattei) seeking preliminary and permanent injunctive relief. The suit requested that the trial court order Scotiabank to recognize the validity of a modified trust deed and to acknowledge the newly designated trustees of Fideicomiso Hispamer. On August 26, 2016, the trial court issued a judgment declaring the suit "No Ha Lugar" (dismissed), finding that the claimants failed to comply with Article 33 of Law 219-2012 (Ley de Fideicomisos) and that the requested remedy was therefore not justified. The trial court dismissed both the interdictal remedy (injunction) and the underlying cause of action against Scotiabank.

Procedural Background

The parties appealed the August 26, 2016 judgment to the Court of Appeals. However, prior to the appellate court adjudicating the appeal, the appellants requested withdrawal of the appeal. The appellate court issued a sentence dismissing the appeal by mutual consent. Subsequently, the petitioners (defendants in the original suit) filed a motion requesting execution of the sentence. They argued that the trial court's dismissal of the suit constituted acceptance of the sentence terms and should be executed. The respondents (the original appellants) opposed, contending that the sentence did not grant any remedy and therefore was not executable. Additionally, they noted that following enactment of Law 102-2017, they had executed an amended trust deed, meaning the trust document referenced in the original suit no longer governed administration of the trust. The trial court issued an order stating: "The sentence of this tribunal is final, firm and inappealable. Both the sentence of the trial level and of the appellate level are clear and precise. There is nothing to provide regarding its execution."

Main Controversies

(1) Whether a judgment that did not grant affirmative relief to either party is executable; (2) Whether changes in governing law occurring between judgment and execution request affect execution obligations; (3) Whether the appellate court should grant certiorari review where factual and legal circumstances have substantially changed; (4) Whether discretionary certiorari review should proceed when a case has become moot due to intervening legal changes.

Position of the Parties

The petitioners argued that the trial court erred by refusing to execute the sentence because they interpreted the judgment as granting relief in their favor. The respondents argued that the judgment granted no affirmative relief to anyone and that the trust deed at issue had been superseded by amendments executed pursuant to a new law.

Holding/Decision

The Court of Appeals denied the certiorari petition and declined to exercise appellate review. The court held that: (1) under Rule 40 of the Court of Appeals Rules governing discretionary certiorari in post-sentential stages, no grounds for certiorari were present; (2) the trial court did not err in refusing to execute a judgment that granted no remedy to either party; (3) the intervening statutory change (Law 102-2017) and the parties' execution of an amended trust deed constituted changed circumstances rendering the original suit moot; (4) moreover, the fundamental issue requiring appellate review—whether the original trust deed complied with Article 33 requirements—had been overtaken by subsequent legal developments; (5) the appellate court would not intervene with trial court discretion absent grave error, prejudice, or crass and manifest error in fact-finding.

Reasons for the Decision

The court applied Rule 40 criteria for discretionary certiorari review, noting that this is an extraordinarily discretionary remedy. The court found none of the seven factors present: (A) the remedy was not contrary to law—the trial court correctly identified that no executable relief had been granted; (B) the factual situation was not the most appropriate for analysis because legal and factual circumstances had fundamentally changed; (C) there was no showing of prejudice, partiality, or crass error in trial court's application of law; (D) the matter did not require further consideration given the mootness; (E) the moot status made this stage inappropriate; (F) certiorari would not prevent unjust fracture of proceedings; and (G) certiorari would not prevent failure of justice given that the parties had executed an amended deed under new legal authority. The court emphasized that when a sentence grants no affirmative relief, it is inherently not executable in the traditional sense. The court further noted that the enactment of Law 102-2017 and the parties' subsequent execution of an amended trust deed rendered the original controversy about the unmodified trust deed academic.

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5. Rios Perez v. Rios Diaz, 2014 WL 7671035 (2014)

Headline

Successor Trustee Lacks Standing to Demand Trustee Removal; Only Settlor, Beneficiary, or Public Official May Initiate Removal Proceedings

Court

Tribunal de Apelaciones (Court of Appeals), Panel integrado by Judges Jiménez Velázquez, Soroeta Kodesh, and Brignoni Mártir

Date

December 16, 2014

Summary of Relevant Facts

On March 28, 2007, Carlos Ramón Ríos Gautier (settlor) executed Public Deed Number Six constituting three trusts for his grandchildren (the children of Ríos Pérez): Camelia Ríos Blondet, José Ignacio Ríos Blondet, and Isabella Ríos Rivera. José E. Ríos Díaz was designated as original trustee. The deed provided that if Ríos Díaz resigned, became incapacitated, died, or was removed, José Ramón Ríos Pérez would serve as successor trustee. If Ríos Pérez could not serve, his brother Carlos Vicente Ríos Pérez would serve as the next successor. On May 8, 2013, Ríos Pérez (both personally and as representative of his minor son, José Ignacio Ríos Blondet) filed suit against Ríos Díaz seeking his removal as trustee. Ríos Pérez alleged that Ríos Díaz breached fiduciary duties by: (1) failing to render annual accounts required by the trust deed; and (2) intentionally failing to inform Ríos Blondet about the trust's existence and purpose, thereby depriving the minor beneficiary of his right to enjoy or claim benefits under the trust.

Procedural Background

Ríos Díaz filed a motion to dismiss and motion for summary judgment, arguing that Ríos Pérez lacked both personal and representative legitimation (standing) to bring the action. The trial court granted both motions on April 1, 2014, dismissing the entire suit with prejudice. Ríos Pérez appealed, contending the trial court erred in using summary judgment to decide issues of legitimation without permitting development of factual controversies.

Main Controversies

(1) Whether a designated successor trustee possesses standing (legitimation) to seek removal of the original trustee; (2) Whether a successor trustee's conditional future interest in assuming the trustee role provides sufficient current injury to bring suit; (3) Whether a parent may bring suit on behalf of minor beneficiaries to remove a trustee; (4) Whether alleged breaches of trustee accounting duties and notification obligations constitute grounds for trustee removal under Civil Code Article 867.

Position of the Parties

Ríos Pérez argued that his dual status—as designated successor trustee and as representative of a minor beneficiary—gave him standing to sue for trustee removal. He contended his appointment as successor trustee created a personal interest in the proper administration of the trust. The trial court (affirmed by the appellate court) held that Article 867 of the Civil Code exhaustively specifies who may seek trustee removal: the settlor, a beneficiary, or the fiscal (public official) in defense of minors or incapacitated persons. A successor trustee does not appear on this list.

Holding/Decision

The Court of Appeals affirmed the trial court's summary judgment, holding that: (1) Ríos Pérez lacks personal legitimation to bring suit because his status as successor trustee is conditional and future-contingent; (2) Civil Code Article 867 provides an exclusive list of parties with authority to seek trustee removal: the settlor (who had deceased), beneficiaries, or the fiscal; (3) a successor trustee's appointment does not confer standing to initiate removal proceedings; (4) Ríos Pérez could pursue the action only in his capacity as representative of minor beneficiary Ríos Blondet; (5) however, even in that representative capacity, the allegations do not establish grounds for removal under Article 867; (6) the trust deed's specification that trustees cannot be required to render accounts outside the deed's requirements and that trustees are not obligated to notify beneficiaries about trust existence means these alleged breaches do not constitute Article 867 removal grounds; (7) the alleged breach of notification rights does not constitute manifest negligence or malversation requiring removal.

Reasons for the Decision

The court applied legitimation doctrine, requiring that a party demonstrate: (1) clear and palpable injury; (2) real, immediate, and precise injury (not abstract or hypothetical); (3) connection between injury and claimed cause of action; and (4) that the cause of action arises under the Constitution or law. The court found that Ríos Pérez's conditional future interest in becoming trustee did not satisfy these requirements. The court emphasized that Civil Code Article 867 exhaustively enumerates removal grounds: (1) incompatible personal interests; (2) malversation, fraud, or negligent administration; and (3) incapacity or disqualification. The court found the allegations did not fit these categories because: the trust deed expressly permitted silence regarding beneficiary notification and did not require separate accounting to beneficiaries. The court noted that while Puerto Rico law recognizes broad fiduciary duties, these must derive from the trust document or explicit statutory requirements, not from general equitable principles alone.

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6. Oriental Bank and Trust v. Perez Mendoza, 2014 WL 5346721 (2014)

Headline

Original Trustee Cannot Resign Through Unilateral Letter; Court Approval Under Civil Code Article 861 Required; Service of Process Invalid When Trustee Status Not Properly Terminated

Court

Tribunal de Apelaciones (Court of Appeals), Panel integrado by Judges Vizcarrondo Irizarry, Colom García, and Steidel Figueroa

Date

September 30, 2014

Summary of Relevant Facts

On October 20, 2005, Oriental Bank and Trust accepted designation as trustee of Fideicomiso Pérez Mendoza. The trust document (Escritura Número 36) provided that Oriental Bank could resign upon written notice to settlors but also contained a provision protecting against conflict of interest. On May 8, 2007, Pérez Santiago, Oliveras Rodríguez, and Pellegrini Castro borrowed $325,000 from Eurobank with the trust serving as collateral. On February 26, 2009, the trust received an additional $90,000 loan from Eurobank. On October 30, 2010, when Eurobank failed and the FDIC took over its assets, Oriental Bank opportunistically acquired both loans to the trust, thereby creating a direct conflict of interest (Oriental Bank became both creditor-lender and trustee-fiduciary). On December 21, 2011, Oriental Bank sent a certified letter to Pérez Santiago and Mendoza Chidiak stating it was ceasing its functions as trustee and gave them 30 days to designate a successor. The letter was returned unclaimed. On November 20, 2012, Oriental Bank sued for debt collection and foreclosure against the trust and its settlors.

Procedural Background

Pérez Santiago moved to nullify service of process on the grounds that he was not an authorized agent to receive service for the trust. Oriental Bank opposed, citing its December 2011 resignation letter. The trial court on July 8, 2014 determined that under the particular circumstances, service through the settlor was adequate. Pérez Santiago appealed. The appellate court granted certiorari review.

Main Controversies

(1) Whether the trust document's clause permitting trustee resignation by written notice supersedes Civil Code Article 861's requirement for court approval; (2) Whether an original trustee may resign unilaterally or whether court approval is mandatory; (3) What status Oriental Bank held after sending the resignation letter—did it remain trustee or cease being trustee; (4) Whether Oriental Bank's conflict of interest (becoming creditor-lender while serving as trustee) triggered any prohibition on remaining as trustee or mandating resignation.

Position of the Parties

Oriental Bank argued that the trust deed's clause 13 explicitly permitted resignation by written notice to settlors without court approval, and that this contractual arrangement governed the resignation process. Pérez Santiago argued that Oriental Bank's resignation was improper and that Oriental Bank remained trustee, meaning service could not be effected through a settlor-non-trustee. He contended Civil Code Article 861 (the antecedent law applicable to the 2005 trust) provided the exclusive method for original trustee resignation.

Holding/Decision

The Court of Appeals held that: (1) Civil Code Article 861 establishes the mandatory procedure for original trustee resignation—the trustee must petition the competent trial court which determines the sufficiency or insufficiency of the resignation reasons; (2) although Article 855 permits settlors to create trusts in any form not violating law or public policy, this flexibility does not permit circumventing mandatory procedural requirements for trustee resignation; (3) clause 13 of the trust deed regarding trustee resignation applies only to successor trustees, not the original trustee; (4) for the original trustee, Article 861 is applicable and dispositive; (5) Oriental Bank's December 21, 2011 letter did not comply with Article 861 because it lacked court approval; (6) therefore, Oriental Bank remained as trustee and service of process could not be properly effected through Pérez Santiago; (7) the trial court erred in determining that service was adequate under "particular circumstances."

Reasons for the Decision

The court reasoned that the irrevocable nature of the fiduciary mandate (established in Article 834 defining a trust as an irrevocable mandate) means that once a fiduciary accepts appointment, unilateral abandonment of the position is not permitted without judicial authorization. The court distinguished between original trustees (whose resignation requires court approval under Article 861) and successor/substitute trustees (whose resignation procedures may be more flexible per trust deed provisions). The court held that permitting original trustees to resign unilaterally would undermine the irrevocable character of the fiduciary mandate and create instability in trust administration. The court noted that Oriental Bank's apparent conflict of interest—acquiring the loans as creditor while remaining trustee—arguably provided legal grounds for removal or forced resignation, but this did not permit Oriental Bank to self-determine its resignation status. Instead, proper procedure would require either: (1) Oriental Bank petitioning the court for approval of resignation on grounds of conflict; or (2) the settlors/beneficiaries petitioning for removal under Article 867 grounds of incompatible interests.

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Summary Notes

The cases summarized above address critical Puerto Rico Trust Law principles including:

• Trust Validity and Registration: The scope of trust creation formalities and whether trusts may hold community property
• Trustee Duties and Removal: Standards for trustee removal, notice requirements, and procedural protections
• Trustee Resignation: Distinction between original and successor trustee resignation procedures
• Beneficiary Standing: Requirements for beneficiaries and representatives to initiate trust-related litigation
• Trust Personality: Recognition of trusts as separate juridical entities capable of being represented in litigation
• Res Judicata: Application of finality doctrine to trust-related disputes

All cases applied the Puerto Rico Civil Code provisions on trusts (formerly Articles 834-874, now governed by Law 219-2012, the Ley de Fideicomisos) while also recognizing principles from Anglo-Saxon trust law adapted to Puerto Rico's civil law tradition.

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