The Chilean Civil Code of 1855 drafted by Andrés Bello was perhaps the most influential codification in the development of Latin American private law after independence from Spain. The Code was not only used in Chile, but was later adopted as a whole in El Salvador, Ecuador, Venezuela, Nicaragua, Colombia, and Honduras. Bello's code was a main source for and influence on the civil codes of Uruguay, Mexico, Guatemala, Costa Rica, and Paraguay.Thus, the Chilean Civil Code was successful not only in Chile, but throughout Latin America.
This article discusses Bello's sources and methods in light of Alan Watson's theory of legal transplants. It provides examples from Bello's drafting of provisions on inheritance law in the Chilean Civil Code and specifically addresses the influence of the Code Napoleon.
M C. Mirow,
Borrowing Private Law in Latin America: Andrés Bello's Use of the Code Napoléon in Drafting the Chilean Civil Code
, 61 La. L. Rev. 291
Available at: http://ecollections.law.fiu.edu/faculty_publications/119