Shortly after the establishment of the consulado of Manila in 1769, a bitter dispute arose between that body and the audiencia for jurisdiction over cases involving the commerce of the Misericordia. On the basis of the cédula of July 8, 1774, the consulado claimed exclusive jurisdiction over all disputes involving trade which arose between merchants. It advanced the contention that in all suits involving losses of galleons the society should be considered in the case of an individual merchant. The audiencia, basing its claims on the royal patronage, declared the consulado to have exceeded its powers, in assuming the jurisdiction described above, and fined several of its members. The consulado appealed the case, and in reply the king promulgated a cédula on June 7, 1775, declaring that neither to the audiencia nor to the consulado belonged the jurisdiction over such cases, but that they should be tried in first instance by the Council of the Indies. [786] The reasons assigned for this decision were that the consulado could not try such cases because merchants constituted its membership and because the fiscal and two oidores also belonged to its tribunal. Neither the audiencia nor the consulado, accordingly, could impartially try commercial suits between merchants and the Misericordia; accordingly thereafter all evidence should be submitted to the Council for special action. The audiencia and the governor had supervision over espolios and vacant benefices. [787] When a prelate entered into office it was his duty to file with the fiscal an inventory of all properties belonging to him at the time of his advent to the diocese. [788] On the occasion of his death a treasury official was designated to estimate and administer the property left, pay the debts of the deceased churchman, execute his will with regard to his property in accordance with the law, and turn over the residue to the royal treasury. This process was known as taking the espolio. The espolio of a deceased prelate was taken, according to the early laws, by an official of the royal treasury, who was designated by the president for the purpose, and who officiated under the supervision of the audiencia. The tribunal verified the autos and substantiated the proceedings of the agent. [789] Whether any modifications in the manner of collecting, distributing or accounting for the funds or properties derived from these espolios were made elsewhere is not clear, but in the Philippines the abuses which arose in the settling of these ecclesiastical estates and benefices made the personal intervention of the oidores necessary on a number of occasions. By royal cédula of June 23, 1712, it was ordered that in all the audiencias of the Indies the magistrate next in rank to the senior oidor should be constituted as the