Obligee's right of subrogation is stemmed from ancient Teutonic law and was first acknowledged in France Civil Code.
债权人代位权制度源于古日尔曼法，始确认于《法国民法典》。
The exercising of the subrogation is limited to the extent to the obligee's right to performance. The necessary expenses arising out of the exercise of the subrogation shall be borne by the obligor.
代位权的行使范围以债权人的债权为限。债权人行使代位权的必要费用，由债务人承担。
The former consists subrogation of real right and of obligee's right.
代位原则包括物权代位和债权代位。
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