Crespo Rivera, Billy v. Dtop Mayaguez
KLAN202400562
Tribunal De Apelaciones De Pue...Jul 18, 2024Background
- Billy Crespo Rivera challenged eight administrative traffic infractions before the Puerto Rico Court of First Instance, Mayagüez Section, requesting judicial review.
- The trial court denied Rivera's request for review and later denied his motion for reconsideration.
- Rivera appealed to the Court of Appeals via certiorari, alleging due process violations and improper evaluation of evidence.
- Rivera argued that the trial court unfairly relied solely on the police officer's testimony and denied him the opportunity to properly cross-examine the witness.
- The Court of Appeals analyzed whether the appellant had properly included necessary transcripts or record evidence to review the allegations and whether appellate intervention was justified under the discretion afforded by certiorari.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due process rights in administrative review | Rivera claims he was denied a fair and impartial hearing. | Department argues the procedure was fair and lawful. | Court finds no due process violation in the lower court's action. |
| Sufficiency of evidence supporting the decision | Rivera argues the judge relied only on police testimony and ignored other evidence. | Department asserts testimonial evidence was sufficient. | Court defers to trial judge's evaluation of evidence. |
| Opportunity for cross-examination | Rivera says he was not allowed to cross-examine the testifying police officer. | Department claims process was adequate. | Court holds the record does not show denial of cross-examination. |
| Proper appellate procedure and record | Rivera seeks review without submitting the full transcript or narrative of the hearing below. | Department asserts this precludes appellate review. | Court denies certiorari for lack of an adequate record. |
Key Cases Cited
- Citibank v. ACBI, 200 DPR 724 (2018) (Appellate review of factual determinations requires showing of manifest error or prejudice)
- Torres v. Municipio Autónomo de San Juan, 208 DPR 586 (2022) (Procedure for judicial review of administrative traffic violations)
- Ortiz Ortiz v. Medtronic, 209 DPR 759 (2022) (Deference given to trial court’s credibility determinations)
- Santiago Ortiz v. Real Legacy Assurance Co., 206 DPR 194 (2021) (Appellate courts must intervene only for irrational fact-finding)