Minera Ygnacio Rodriguez Ramos v Bartlesville

• Date: 01 January 1925
• Court: Texas Supreme Court
• Docket Number: Case No. 47

Supreme Court of Texas.

Case No. 47

Cia. Minera Ygnacio Rodriguez Ramos, S.A. (plaintiff)

and

Bartlesville (defendant).

Recognition of Belligerency — Distinguished from Recognition of Government — Effect of — Invalidity of Acts of Unrecognised Government in Foreign Court — Decrees of the Revolutionary Villa Party in Mexico.

The Facts.—This is an action for damages arising from an alleged conversion of ore in Mexico. The ore was taken from plaintiff and confiscated by General Francisco Villa in Mexico, sold to parties in that country, and shipped to Texas, where it was purchased by defendant in good faith. The Villa forces were in control of a large part of Northern Mexico and ruled it by paramount force and exercised governmental powers therein. Civil war existed, in which the Villa forces were contending with those of Carranza. The Villa forces were unsuccessful, though they were recognised as belligerents by the United States Government.

Held: for plaintiff. The seizure and sale of property in Mexico by the Villa forces under these circumstances could not pass title to the property. The recognition of the Villa faction as belligerents could not confer upon it any sort of recognition as a Government; and...