Adm De Terrenos De Puerto Rico v. Hernandez Degross, Rene, KLCE202301346

The Administration of Land of Puerto Rico (the "Agency") filed an action for eviction (desahucio) against René Hernández Degross and his wife, claiming illegal occupation of agency land in Vieques.
Hernández Degross responded, claiming ownership of the land by usucapion (adverse possession) and sought to convert the summary eviction action into an ordinary proceeding to resolve the property title dispute.
The Agency amended its complaint to add co-defendants, including Hernández Degross's daughter, and the court (TPI) gave Degross 10 days to respond, but he filed much later.
The TPI refused to accept the late answer and entered "rebeldía" (default) against Hernández Degross in both the eviction and a related damages action, denying multiple requests to set aside the defaults.
Degross continued to participate in the litigation and attempted multiple times to have the defaults set aside, arguing both substantive defenses and personal hardships affecting timely filing.
On appeal, the Special Panel of the Puerto Rico Court of Appeals addressed whether the TPI erred in refusing to set aside the defaults, given the defendant's ongoing efforts to litigate and substantive defenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the default (rebeldía) properly entered against Degross in the eviction action?	Degross failed to timely answer, so default was proper.	Degross actively litigated and had substantive defenses; default was too harsh.	Default was improper; TPI should have set it aside given active defense and no notice/warning of sanction.
Should the TPI have accepted Degross's late answer to the amended complaint?	Procedural rules require a timely answer; timeline was not met.	Case was converted to ordinary, so answer should be allowed for merits.	TPI should have allowed late answer and let case proceed on merits.
Was default appropriate in the damages action for failure to answer timely?	Failure to answer justified default entry.	Ongoing, good faith litigation and meritorious defenses justified setting aside default.	Default should have been vacated; TPI abused discretion by not doing so.
Could TPI revisit its prior sanctions orders, or was it bound by prior determinations (law of the case)?	Prior denials of relief were final and should not be relitigated.	TPI retains power to revisit non-final/interlocutory orders for justice.	TPI could and should have reconsidered defaults, especially where their maintenance caused injustice.

Rivera Figueroa v. Joe's European Shop, 183 DPR 580 (courts must interpret default liberally and favor adjudication on the merits)
Banco Central v. Gelabert Álvarez, 131 DPR 1005 (doubt on default status to be resolved in favor of party seeking to set aside default)
Neptune Packing Corp. v. Wakenhut, 120 DPR 283 (factors for setting aside default)
Dávila v. Hosp. San Miguel, Inc., 117 DPR 807 (extreme sanctions only in extreme cases)
Sánchez Rodríguez v. Adm. De Corrección, 177 DPR 714 (purpose of sanctions is not to cause injustice, but to ensure case management)
Mgmt. Adm. Servs. Corp. v. ELA, 152 DPR 599 (law of the case doctrine is flexible, subordinate to justice)