Duchy Original: The Palma Title At Home and Abroad

With the alleged financial peccadilloes of the Duke of Palma de Mallorca receiving so much media attention, perhaps it’s a good time to consider whether or not there is any such person.
Of course, any number of references may be found on the internet and in print media to Iñaki Urdangarín as ‘Duke of Palma de Mallorca’. These are only potentially accurate inasmuch as he may be considered – at most – Duke Consort: the Royal Decree bestowing the Palma title for life on the Infanta Cristina, daughter of King Juan Carlos (the official text of which may be seen at this link) makes no mention whatsoever of the person to whom she shall be married; the Decree only says that the title is bestowed with occasion of her wedding.  
In earlier times the consequences of this would have been straightforward enough, but in 1987 Spain enacted a piece of legislation of the same degree in law, a Royal Decree regulating the titles, honours and forms of address of the royal family. Under Article 6 it specifies that the use of titles vested in the Crown will be ‘personal and for life’. Most interestingly, this article was followed by a Transitory Disposition stating that:
– King Juan Carlos’ father would continue to hold the title of Count of Barcelona for life; and (most importantly to the present matter)
– King Juan Carlos’ mother would continue to receive the same title and corresponding honours.
The very fact that this Royal Decree mentions the King’s mother, and the status to be accorded her, appears to be a tacit admission by those who prepare such things for the King’s signature that some explicit mention of the King’s mother was necessary in order for her husband’s rank and precedence to extend to her; otherwise, it would not do so.
No such mention of the Infanta Cristina’s husband is made in the Royal Decree granting her the Palma ducal title, nor does the 1987 Royal Decree governing titles and forms of address for the Spanish Royal Family take up this issue with a view to future marriages.
Earlier Spanish jurisprudence had held that ‘husbands and wives shall enjoy the honours of their consorts’ (Article 64 of the Civil Code) but this was repealed in 1981, and the wording of the 1987 Royal Decree seems to constitute admission by the Royal household of the fact that the new situation also extended to the consorts of those bearing titles vested in the crown. A well-known Spanish expert in matters nobiliary, the Count of los Acevedos, discusses this topic on page 71 of his work ‘Historia y régimen jurídico de los títulos nobiliarios’ as it applies to other Spanish titles of nobility. Previously the late Juan Balansó, a prolific writer and expert on the Spanish Royal family, had expressed in his 1998 work ‘Los Diamantes de la Corona’ the opinion that the royal sons-in-law were not strictly speaking entitled to be referred to with the ducal titles.
Of course, the law is one thing and custom something else. A Google advanced search of the Spanish Monarchy’s official web site uncovers numerous instances of Iñaki Urdangarín being referred to as Duke of Palma, even in remarks made by his wife the Infanta; but it is noteworthy that the official biographical page about him, on the same site, does *not* refer to him by the title. In Spain as elsewhere people are accustomed to considering a Count’s husband a Countess, and a Duchess’ husband – apparently – a Duke. In the end one gets the feeling that the title was probably granted to the Infanta more with a view to providing her husband with precedence he would not otherwise enjoy at events outside Spain, and that little importance was attached to whether or not it made him a Duke under current Spanish law. If one assumes that in most other countries, to the extent that titles are even used or recognised at all, consorts do still receive the styles and forms of address accorded to their spouses, then – ironically – it may be more correct in a legal sense for foreign media to refer to Mr Urdangarín as the Duke of Palma, than it is for Spanish media to refer to him as el Duque de Palma and by so doing to flout the Civil Code and a pair of Royal Decrees.