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Codified Systems and Constitutional Supremacy (Tribute to Juan Bautista Alberdi)

Author. Sergio Fabián Ríos.
(Teacher)

                                   Universidad del Salvador                                  
                                   Buenos Aires. 
                                   Argentina.             

I.- Introduction.

The Romans called "Constitutions" to the supreme decrees dictated in full exercise of the omnipotence of the state, where the only life boss enjoyed a fearsome power abuse and oppression exercised over the inhabitants of the kingdom as well as on foreign enemies. [See Antagonismos Políticos y Sociales en Roma. Historia de Roma, Books I y II Volume 1, Theodor Mommsen].

Meanwhile, -such as The Academic Reinaldo Vanossi teaches-, the Constitution on the Greek polis was considered more on the idea of organization than the concept of regulatory and normative supremacy pertaining to relations between society fundamental principles and the state. ["University and Constitutional Law. Fortunes and misfortunes of the chairs "].

It is clear then, that the term "constitution" meant something very different for constitutional democracies since the Republic of Weimar was installed, which meant in Rome with full respect for the dictates of the "dictator or village chief" Roman, in terms of the height of abusive exercise of power. [An example: The reign of "Tarquinius Superbus 534-509 BC].

It will take much time and civic developments to understand the constitutional texts as we know them nowadays. It must have abandoned the idea of military glory as the supreme object of ambition and see instead people moving freely, placing their constitutions in the proper position, with its "normative hierarchy" , linked to the progress and prosperity, to safeguard social organization and protection of individual rights.

Has been claimed a definitive and conservation constitution as opposed to those of transition and creation Constitution proclaims [1852 in Argentina]. [Juan Bautista Alberdi. "Bases" and starting points for the political organization of Argentina, hereinafter called "Bases"].

In Latin America, Juan Bautista Alberdi, -Inspirator of the Constitution of Argentina Republic-, had already rejected by the year 1852, most constitutions in force in South America. Contrary quoted glowingly, the California Constitution of 1849, which he named as "confirmation of the constitutional basis for Argentina".

He stressed his text saying he was "full of anticipation, good sense and opportunity [and opportunity in each of its provisions ...] everything is simple, positive practical, while being worthy ..."

In terms of “absolute rights”, as those were called by Alberdi and Velez Sarsfield in the controversy over the Civil Code, Alberdi stressed the contemplation of California Constitution, and held it should not be specific matter to a Code issues, except at most, of regulations of its text.

So, Alberdi emphasized that the Constitution -on matters such as "education and training of families", giving the rank of "sanctity of the family" as a hotbed of State of the Republic-, was the only seedbed of fertile population and social regeneration. Brought to quote some passages of that Californian Constitution which read: "The legislature will protect by law certain portion of the home and other property of every householder, to avoid the forced sale (art 9th, section 15.) "

Elsewhere in his work “Bases”, said that the California Constitution applies directly and inviolably for the support of public education, a part of state assets and thereby guarantees the progress of their new generations against abuse or neglect of the government. Makes education a fundamental basis of political agreement. (Title 10). [Bases].

He also noted that the same Constitution provides for equal tax on all state property, and lays the foundations of the system of direct contribution, which is befitting countries called to receive from abroad all its development, instead of the customs tax. In support of real credit, prohibits the legislature grant privileges for establishment of banks: strictly prohibits the issuance of all comparable to paper money issuing banks ... [bases].

Meanwhile, in Chapter XVI of "Bases", Alberdi maintains that civil and commercial law should not reject foreign benefits that the Constitution attracts, since what would gain for one side would be lost for the other. He said that "freedom in the Constitution but chains in regulations and law, is a sure way to discredit the new system of government and maintain the backwardness of these countries". With respect to the latter we can see that the sense of freedom that comes with the Constitution, -according to Alberdi-, is not shared by the rules of inferior rank as laws and regulations.

In an attempt to convert the Constitution in the hierarchically higher standard, [articule 31 of The Constitution of The Argentine Republic], Alberdi said it was necessary that civil laws and trade processing are modified and designed within the meaning of the same trends that should govern the Constitution, and cited some examples of how regulatory laws (organic according to his sayings) could alter the spirit of constitutionally enshrined, namely freedom: "the press is free, says the Constitution; but may come the organic law of the press and create as many obstacles and limitations on the exercise of that freedom, as to let her illusory and deceitful "; It's free suffrage, the Constitution says, but come the electoral organic law, and force requirements and limitations will become exceptional Lie freedom to vote; so with free trade, etc.

• Universal movement of codification.

Alberdi did not agree with the universal movement of codification, while recognizing its inevitable advance. Against this, highlighted the immense benefits of the French Civil and Commercial Code, on which considered that the application had well deserved in the middle of Europe as it was done.

He saw, mainly in the Civil Code (both french and argentine), its roots in Roman law, patrician for inspiration.

In his famous controversy with Velez Sarsfield [author of the Argentine Civil Code entered into force in 1871] was strongly opposed its enacted. He was concerned the relationship between the Code and the Constitution; its extension; forgetting the (Argentine) national sources as accused him of "copy". Argued that it was a contradiction that the independence revolution were proclaimed in the Constitution while the old colonialist regime was intended to be represented in the Code. Predicted that paradoxes such as "democracy in the regime of State and autocracy in family law would occur; Democracy in the city and absolutism in man".

He argued that the idea of a code was incompatible with the idea of a country composed of many sovereign or semi-sovereign states [Argentine federal system consisting of autonomous provinces].

As for the criticism of the extension of the Code, Alberdi added that the Codes of freedom should be short. It is not true, he said, that each article of the Code represents a freedom so that, the more bulky the freer. To enshrine freedom, the article into a Code is not needed, just the contrary, its omission.

He continued repudiate the sanction of a civil code saying, "In a country that seeks free, freedom is presumed, the restriction is expressed. The silence of the law is the voice of freedom".

The truth is that since 1871 in Argentina, coexist a constitutional text (Constitution) and Civil Code about which I will write in the next lines.

II.- Codified system vs. non codified system.

At the dawn of the French Revolution, freedom and individual rights, -at such a glut of oppression and indifference against the people- they became the cornerstone of popular clamor.

The result of the revolutionary conquest laid the foundation for the proclamation of a Constitution firmly rooted in values of liberty as inalienable and indivisible right of mankind.

Those same values built the foundation of the Constitution of The United States of America (US), and most certainly inspired to our Founding Fathers, watered these libertarian and democratic ideals, a process that was enshrined in the Argentine Republic, with our nowadays in force Constitutional Text of 1853.

These important links based on inalienable values unite us Constitutionally from the eighteenth century and are the strongest bond of civility that we have so as to resist the tyrannical onslaught.

Under these assumptions there is no infra-constitutional legislation -including the "codes" - that can alter that foundation which falls within the principle of the supremacy of the Constitution.

So, we analyze, the well known division between the systems' coded "and" uncoded "among which preferentially found, the system of" common law "subject, both of them, to the Constitutional Supremacy Rule.

We wonder if both systems are incompatible between them, and must be kept into a rigid division to the point of mutually waive to a valid and appropriate interaction to finding fair solutions to cases that are dealt in their respective courts.

From the standpoint of the coded system would be improper to apply the Roman maxim 'dura lex sed lex' to laws of dubious constitutionality, even if it is the same line of interpretation in many cases wrongly presented as the sacrosanct solution to all the problems in a community.

This means above all that, that the systems coded or uncoded, should not be the priority in the analysis of a specific case or the last interpretation in the application of positive law, since the priority is set by the search for truth for the fair solution. The violation of a right must have its counterpart in their care. The guardianship should be sought primarily under the Supremacy of the constitutions of liberal extraction '

An analysis in contrary would mean that the case should be adapted to current legislation at the expense perhaps of justice itself, when in fact, law application has to be exactly the opposite, for where there is a right must be a remedy law that covers it, always with maximum "alterum non laedere" which Roman law looked despite its absolutism.

Similarly but this time in the system of “common law”, the precedent prevalence might not be to the detriment of the Constitution that makes to its own democratic system.

a)    Codified systems and the common law.

It is not new that there are criticisms for and against of both systems.

Here are some of those criticisms, starting for the codified system:

Some reviews for:

1) It provides a set of general principles within which they have to frame the factual cases.

2) This gives itself, the scientific note to coded system.

3) It is predictable, because of its own limits, so as the judge works within those legal limits of the Code.

4) It put the code in the center of the legal scene with the most and the least that this brings to standards of Superior Hierarchy. Here is the big issue linked to the Constitution.

5) Grants part of the solution to the problem of regulatory dispersion, gathering almost everything, in a single body of civil and commercial law.

Some criticisms against:

6) The lack of plasticity in the practice of law, because of the  general principles subject to the rigid texts, guides the proceedings over finding just solution of the"case", because actually happens in practice that seeks preferably not injure the law, forgetting in many cases, to protect the right that needs protection as a primary task of this science.

7) Establishes, with a static policy, and a systemic order, that will not adapt to the dynamism of reality, demanding of judges, re-adaptations to grant equitable solutions without offending the principles contained in the Code.

8) The full force of the Code becomes a Sub-Constitution.

Critical, both for and against the system of "Common Law":

Some reviews for

1)    Not subject to legal principles for analyzing the "case".

2)     Despite the absence of that scientific note, there is no risk that legal principles take precedence to the finding solution.

3)     Coherence. Prevails the "precedent" to the application of legal precepts, avoiding strictly certain circumstantial majorities in Congress or Parliament so to impose certain bills that can attempt against the rules of the Constitution.

4)     The mechanism of the "precedent" achieves continuity, since the law that inspires them is the Constitution of the Nation, avoiding inferior standards that could obey conjunctural issues.

5)     No preferably to be subject to the lower positive law before the Constitution.

Some criticisms against:

6)    The great power given to judges has to be accompanied by the composition of a respectable judiciary, which adheres to the Constitution, and be far away from political issues. Llambías has called this the reign of the judges.

7)     The absence of scientific note, is based on to the system is out of "legal principles" interpretation. The common law does not discuss the case or thinks in terms of general principles of law, but through its precedents judicial accompanying his approach.

8)                     Finding the right precedent for the case to be heard at a given moment, a   Herculean task for legal practitioners. Today, the difficulty has been mitigated thanks to the internet.

* Code and Constitution. Operability and inoperability of Constitutional Clauses.

It is questionable whether the coded systems are doomed to resolve disputes under its rigid structure or conversely can lift his head to look further and in particular, to address the rights and guarantees provided for in the Constitution and render them operational. And in this regard, we ask what happens to the rights derived directly from the Constitution.

To answer the latter, we must necessarily refer us to the resolution of emblematic cases we have in the annals and continue to guide us in everyday legal work.

At the end of the eighteenth century "Joaquín V. González" said: "They are not, as may be believed, declarations, rights and guarantees simple theoretical formulas: each of the articles and clauses that contain them have binding force to individuals to the authorities and the entire nation. Judges must apply them in the fullness of its meaning, without altering or weaken with vague or ambiguous the interpretations express meaning of the text. Because they are self-defense, the unchanging heritage that makes every man, citizen or not, being free and independent within the Nation of Argentina".

This quote brings to mind, the sentence of Judge Alfredo Orgaz, nothing less than in the famous "Siri" case, who argued the same idea when he resolved as member of the Supreme Court of Argentina.

Recall that in this case, the Supreme Court had to resolve the request of a defendant who had not, at that time (1957), a legal figure to invoke his right; However the Court ruled in his favor, laying the foundations of the today known as "amparo action" by revoking the lower court judgments.

The Supreme Court, in particular the illustrious minister Orgaz, saw in that case, beyond the current positive law and focusing on it, opened its value in the justice mind rather than in the absence of a law contemplated the "amparo action" not legislated by that time.

The following year, in 1958, the Supreme Court when it ruled in "Kot" case, not only referred to above mentioned - "Siri" case - but emphatically said, "... Trying overly technical constructions to justify this distinction, involves to interpret the Constitution so that it appears sheltering not only essential rights but gross violations of human rights ". He said further: "... Such guarantees not unilaterally serve the aggressors, to draw distinctions between them, but those attacked, to restore their basic rights"

This leads to the thought of Alberdi, and according to him, the concept of law, must be conceived as "the moral rule of human conduct" which aims to connect or bind men together for the realization of their respective development.

Specifically, Alberdi appreciated much more the essence in implementing the law than stringency forms so admired by the Romans. This was made known by highlighting for example, in the book "Twenty days in Genoa" when he paused in thought as follows: "The Genoese lawyer's practice, to refrain from using garlands and jasmine rhetoric, which could jeopardize the simple austerity of the truth. Do not put more fire than the conviction, which does not mean to speak without heat. They are so sober expressions of respect and deference to the judges, as economic in terms capable of displeasing".

In this context, putting the focus on the field of legal dispute exists reasonable suspicion that the immediacy that offer codes and positive legislation generally move in many cases the rights and guarantees stemming from the constitutional text.

Conspires against the latter, technical spoiled, dividing the constitutional clauses on "operational" and "non-operational" which in many cases has the perfect excuse for not applying, despite its supremacy.

In practice, the operation or functionality of a constitutional clause depends on the discretion of judges that is to say, if the clause is directly applicable or not operational, regarding to a constitutional clause without regulation. Before that, the fate of legally protected depend on that discretion, running the risk that an injustice could be committed by the lack of implementation of a constitutional right due to non-operability, which culminates in which safeguarded the norm at the expense of justice value.

Without fear, I believe that this division between operative and non-operative clauses, has been one of the most perverse attacks that happened to the effective implementation of constitutional law and hence to the "Justice".

Indeed, this division put a fence very difficult to reach the Supreme Text of the Constitution discouraged its full enforcement for years, restricting its importance to issues of political organization and poor application to regulations  regarding to the supremacy in the field of fundamental rights relations between society and the State and between private individuals

• The constitutionalization of the Argentine Civil Code.

What do we talk when we addressed the issue of the constitutionalization of the civil code?

From the experience of schools of law, many years ago it is taught, [whom we follow the classical authors such as Llambías], that the sources of law are "The Law", "The Tradition", "Jurisprudence", "The doctrine of the authors "," Equity "and" Comparative Law "

However, the Civil Code of Velez Sarsfield, [Article 16], whose validity will expire in August 2015, states: "If an issue cannot be resolved, not by words, or the spirit of law, shall address the principles of analogous laws; and even if the concerned has been questionable, it was resolved by the general principles of law, considering the circumstances"

Directly, this implies that the Civil Code does not nourished by different sources, except, those this articule indicates. Perhaps that was the intention of Velez Sarsfield?

Whether the jurisprudence in the course of time, has gone further that this “corcet” imposed, the fact is that Vélez limited sources to the articule 16, moving away from the Constitutional text. Step to explain the latter.

This leads firstly to analyze the thinking of Vélez at the time this jurist begins his studies writing the Civil Code and in particular, calls us to realize on the degree of attention that would have rendered to the Constitution of 1853 during his studies of the the Civil Code of Argentina started in 1864 and in force since 1871.

Although the studies began 11 years after the Constitution was effective, the Code of Vélez does not register a single mention in all its articles, about the “Magna Carta”. But, just children would attribute this failure to the sustained controversy with his counterpart, Juan Bautista Alberdi, since the issue occurs with other overtones of depth from point of view of analysis of law.

Indeed, the drafting work of Velez Sarsfield, had in view other sources. He considered for it, the Roman law, the very respectable French Civil Code, authors such Aubry and Rau, Savigny, the outline of Teixeira de Freitas, the work of Andrés Bello, among others. That is, their line of work was passing by different lanes than those that inspired Alberdi to the text of the Constitution. For example, while Velez was studying the real right of "domain" under Roman law, Alberdi stressed freedoms contained in the Constitution of the State of California.

While this lack of complementation did not bring an incompatibility between the two sets of rules, because in fact, as noted above, have lived in Argentina society for over a century; however it had installed criteria on a very different legal analysis, for instance, the prevalence on individual rights and freedoms are strongly attributed to the Civil Code rather than the Constitution. Is it real?, I think it is more an illusion or a practical convinience, than a real thing, so as we mentioned above, the fundamentals right are contemplated in the Constitution, and is correct to be like this.

The Civil Code is intended that each item is a freedom, a right or a limitation. This made of it, a regulatory body extensive and voluminous, the Code. By contrast, in accordance with the thought of Alberdi, Codes of freedom should be short. According Alberdi is not true that every article represents a freedom. To enshrine freedom, the article into a Code is not needed, just the contrary, its omission is needed. [View Alberdi-Vélez Sarsfield Controversy].

I share the thought of this illustrious thinker [Alberdi] because freedom as well as the ability of people, it is a presumption. It is not expected that a legislative text list freedoms besides  of its limitations. And this happens with fundamental rights such as freedom of speech and press, the presumption of innocence, the right to travel freely in and out of the country, the right to exercise any legal industry, the right of association, etc.

On the contrary, I do not agree with Alberdi and yes I do with Velez Sarsfield, about “absolute rights”, such as both of them denominate those rights, which in fact refer to the "fundamental rights" must not be regulated by the Civil Code, as the Vélez himself acknowledges that they have a higher status than a simple civil law, because any day could also be revoked by Congress depending on circumstantial political majorities. These rights, said Velez, are entered in the political code in the Constitution, which should only be because the civil code is not its place.

Narrated far in this section gives a rough idea of how far was one text from the other; civil law or civil code and the Constitution.

This problem did not go unnoticed by the most authoritative doctrine Argentina. But little was done so far to resolve this dilemma, based on a kind of dispute between the Supremacy of the Constitution and strict and privileged application of the Civil Code and the general principles of law.

This point is not only expressed in a simple choice about whether judges preeminently apply a text on the other, but the question is incarnate in the Argentine legal practitioner as a "right mindset". This mechanical way of thinking -more of Argentine law- to find the right solution, not always becomes the ultimate aim pursued, as it is often displaced by the preconception priority of the law as a science in order not to damage it, instead of thinking of doing justice in the case.

The latter should not happen if for example, would prevail in domestic law, constitutional supremacy under the articule 31, beyond the unfortunate concept of operational or non-operational clauses, whose creation served only to hinder the full constitutional text as we said above.

For some years a part of the Argentina doctrine, it has been proposed to bring the Civil Code to the Constitution.

The prestigious "National Academy of Law and Social Sciences" of Argentina, work on it with the overturning of views and works of prominent jurists.

Indeed, the proposal was intended to be presented as the "modernization of the law", but, to tell the truth it responds to a belated recognition of the unjust alienation of positive law to the Constitution.

The Argentine Civil Code in force from 1871 to 2015 ruled the daily lives of its inhabitants with a clear predominance over the Constitution.

As mentioned above, this mindset has installed a legally system governed by the codification.

Early on, the training of lawyers in the School of Law at the Argentine Republic, is focused in terms of "principles and the legal framework to be applied to the case presented". This legal structure belongs mainly to the Civil Code, except specific matters of constitutional law, when in truth, the latter should be present and not only focally, in the study of all matters of law, whatever the discipline is about.

The new Civil and Commercial Code of Argentina to take effect in August 2015, certainly provoked a great impact in the Argentine legal operator. Such shock led to bar associations, law schools, universities, publishers and others, should immediately to schedule refresher courses to halt the anxiety of lawyers, joined the hasty decision of its enactment, whom imagined in a moment, deprived of their basic tool.

It is possible to show that this impact suffered by the imminence of the new Civil and Commercial Code, was not envisioned so clearly when it occured the last constitutional reform of 1994, because, beyond logic concerns on the modification of the organic part of the Constitution , -such as, duration of the presidential term, the limited-election and some concern about what would happen with the dogmatic part of the text, referring to the rights and guarantees; it was not noticed in the legal operator, a similar notorious concern as happened with the implementation of a new civil and Commercial Code of the Nation.

Someone will say, it was logical that not cause a similar stupor the constitutional reform, as happened with the new Civil and Commercial Code, because the rights and guarantees provided for in the dogmatic part of the Constitution were not altered. While this is true, strictly speaking, the constitutional reform incorporated new rights and guarantees, such as consumer rights, access to information, habeas data, among others. Anyhow, to the date, in many judgments not even take in account and worse, ignore his constitutional entrenchment, as for example with the figure of "affected" in terms of consumer rights provided for in art. 43 of the Constitution.

The President of the Supreme Court of Justice of the Nation, gave many presentations in regard to the new Code, which is one of its authors. He had to bring calm to lawyers and judges to say that the new standard should not worry because mainly tried to gather in this new regulatory body, the latest case law already applied in various forums.

The truth is that such an impact with the enactment of a new Code, involves altering one of the most basic tools for lawyers who have to practice law in its two expressions such as counseling and litigation. The attachment of the legal operator to the Civil Code is clearly different to what happens with the Constitution.

Now the question arises regarding to the new Civil and Commercial Code, if it gives reply to that current of constitutionalization of civil law. [Code].

No doubt that has been achieved in certain aspects, significant progress on put close to the new Civil and Commercial Code, the Constitution. For example, on the general principles of consumer protection has been established guidelines that act as minimum protection.

In the field of interpretation a "dialogue of sources" [Draft Civil Code and Commercial Procedure] is set, so that the code retrieves a centrality to enlighten other sources.

But this interpretation mainly encouraged to read from the beginning in the text of the new code [Preliminary Title. Chapter 1. The right] Article 1 says. Sources and application. Where this Code applies must be resolved according to the laws that are applicable. The interpretation must comply with the Constitution and treaties to which Argentina is party ...

It is very important that from the beginning, the first article of the new Civil and Commercial Code, mentioned the Constitution, which did not occur with the old civil code.

Now, we wonder, is this enough to consider that there has been the constitutionalization of the new Civil Code?. The answer is clearly "no", because as we indicated above, the legal operators in Argentina have the mechanics of thought put into the general principles of the Code and not in the text of the Supreme Law, except for particular issues. So as has repeatedly said the co-author of the new Code, Dra. Kemelmajer Carlucci, with this new code should change the mindset of judges and all legal operators.

In order the changes embodied in the new Code be effective, judges, lawyers and all the actors of Law involved, should change their pattern of thought and adapt to the new era which aims install this huge company.

Corollary.

To achieve the proper interaction of the Civil Code and the Constitution, it is required that the text of the latter be put at hand easily as it is easily handy the civil code for law operators.

It is therefore imperative that the rights and guarantees provided for in the Constitutional text be put in function without exception nor excuses.

Judges and lawyers, the latter by promoting the causes involved, should take into view the value "justice" and the protection of the rights involved, above the regulatory rigidity which has often spoiled the ultimate purpose of the rights which lies mainly in achieving "justice" what will become in social peace in the community.

Regardless of whether a nation is subject to the coded system, you cannot lose sight of one source as important as is "customary" law, since it precedes the law and how Linares Quintana says, remains at your side to translate aspirations.

This source provides another point of reconciliation between the codified systems and the "common law". She will help to moderate the sharp division between the two systems, implementation and interpretation of law, when all he brought so far is the famous "legal scandal" by arriving at different solutions in similar cases, where necessarily one of them will have been unjust. While this thought is usually applied to domestic law need not be alien to international law, at least in the Western world who share "constitutional democratic" systems with similar values.

What evolved was believed to pass from the custom that prevailed in ancient times, to the written rule, devoted to the broad task begun by Napoleon and then extended during the XIX century in the whole civilized world [Treaty of constitutional interpretation. Second Linares Quintana. Tribute to Karl Loewenstein] really meant a model of inflexible thinking in the interpretation and application of law, due to the rigid nature forcibly containing the law into their statements.

Both the usus iuris as the common conviction of social behaviors are elements of social dynamics that can not be immersed into watertight compartments. The safe conduct of this is the constitutional text content short and blunt, with predominance of liberty without more detail in their field with, of course, the limit not to harm anyone.

Mainly, the Code shall regulate the relationship between individuals and in some respect with the state, but must not forget their inferior hierarchical status to the Constitution where we will find our own limit and guidance in interpretation.

 Bibliography [cited in order of appearance into the text]

• History of Rome, Books I and II in Volume 1, by Theodor Mommsen.
•  University and Constitutional Law. Fortunes and misfortunes of the chairs. www.ancmyp.org.ar. Jorge Reinaldo Vanossi.
•  Controversy between Juan Bautista Alberdi and Dalmacio Velez Sarsfield regarding to the Civil Code.
• Press Freedom. Gregorio Badeni. Editorial. Abeledo Perrot June 6, 1997.
•  Bases "and starting points for the political organization of Argentina. Juan Bautista Alberdi.
•  Constitution of Argentina.
•  Treaty of Civil Law. General Party. Jorge Joaquín Llambías. Editorial. Abeledo Perrot.
•  Treaty of Constitutional Interpretation. Tribute to Karl Loewenstein. Author. Second V. Linares Quintana. Editorial. Abeledo Perrot 2008.
•  Twenty days in Genoa. Juan Bautista Alberdi.
•  Several works published on the website of the "National Academy of Law and Social Sciences" of Argentina "www.acaderc.org.ar
•  Civil Code of Argentina.
•  Text "Draft Civil and Commercial Code of the Nation Argentina"

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