Dth Corporation v. Municipio Autonomo De San Juan, KLAN202400036

DTH Corporation sued the Municipality of San Juan over unpaid invoices totaling $116,800.42 for services rendered for debris removal after Hurricane Maria, specifically from November 4 to December 16, 2017.
The parties had a written contract, signed by DTH on Nov. 20, 2017 and by the Municipality on Dec. 19, 2017, establishing contract validity from Dec. 19 to Dec. 31, 2017 and registered with the Office of the Comptroller on Dec. 29, 2017.
DTH submitted its claim on the basis that it had performed the work, and sought payment, costs, expenses, and attorney fees.
The Municipality argued that payments could not be made for services predating the effective and registered contract period, as required by Puerto Rican law for governmental contracts.
The trial court granted summary judgment in favor of the Municipality, finding DTH could not recover for services rendered before the contract’s effective date. DTH appealed, arguing the state of emergency and executive orders should allow for payment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are services prior to the written contract’s effective date payable?	DTH: Work was performed by mutual agreement and should be paid.	Municipality: No binding contract covered disputed period.	No payment because no written, registered contract existed.
Does the emergency executive order waive all formal requirements?	DTH: Governor's order removed contract registration requirements.	Municipality: Only covers state, not municipalities; still needed.	Emergency order did not waive the written contract requirement.
Can registration with Office of Comptroller be enforced retroactively?	DTH: Registration was an administrative step, contract existed.	Municipality: No retroactive effect, must be registered before.	No, registration must precede demand for payment.
Does equity or unjust enrichment support DTH’s claim?	DTH: Services provided, not paying is unjust enrichment.	Municipality: Law controls; public funds require strict compliance.	No, law controls over equity in government contracts.

RMCA v. Mayol Bianchi, 208 D.P.R. 100 (P.R. 2021) (defines liquid and enforceable debts in the context of collection actions)
ALCO Corp. v. Mun. de Toa Alta, 183 D.P.R. 530 (P.R. 2011) (government contracts require strict compliance with statutory prerequisites)
Quest Diagnostics v. Mun. San Juan, 175 D.P.R. 994 (P.R. 2009) (private parties bear risk of non-compliance with municipal contracting requirements)
Vicar Builders v. ELA, 192 D.P.R. 256 (P.R. 2015) (written contracts are indispensable for binding government contracting)