In re: Adelaida Arroyo Brito
2025 TSPR 62
Supreme Court of Puerto Rico2025Background
- Adelaida Arroyo Brito, an attorney and notary admitted in 1990, was subject to disciplinary proceedings before the Puerto Rico Supreme Court.
- The Office of Notarial Inspection (ODIN) detected substantial noncompliance regarding her notarial records, particularly missing volumes of the Book of Testimonies and significant deficiencies in required fee payments.
- Arroyo Brito failed to produce complete records for inspection, did not submit required documents despite multiple opportunities, and accumulated an arrears of over $200,000 in notarial dues.
- The Court and ODIN repeatedly ordered Arroyo Brito to provide missing records and justify her noncompliance; Arroyo Brito cited unspecified personal reasons and requested additional time but did not fully comply.
- The Supreme Court issued an immediate and indefinite suspension from both law and notary practice and referred the matter to the Department of Justice for further investigation of the fee shortfall.
Issues
| Issue | Arroyo Brito's Argument | ODIN's Argument | Held |
|---|---|---|---|
| Failure to comply with notarial record requirements | Cited personal reasons for noncompliance and requested more time | Demonstrated pattern of neglect that undermined public trust | Suspension and referral for investigation |
| Deficiency in notarial fee payments | Claimed to possess the necessary seals for unregistered testimonies | Detailed large arrears in unpaid notarial dues | Held: Noncompliance justified severe discipline |
| Repeated violation of orders by Court and ODIN | Offered apology and partial documentation | Pointed to ongoing, systematic breach of professional obligations | Suspension from law and notarial practice |
| Requirements to return client files and unearned fees post-suspension | Did not address specifically in motion | Required by ethical and procedural rules | Ordered to notify clients, return files/fees, certify compliance |
Key Cases Cited
- In re Cardona Estelritz, 137 DPR 453 (P.R. 1994) (strict compliance with notarial duties and immediate response to deficiencies is mandatory)
- In re Amiama Laguardia, 196 DPR 844 (P.R. 2016) (attorneys must promptly address deficiencies and orders from Court and ODIN)
- In re Alers Morales, 204 DPR 515 (P.R. 2020) (persistent failure to comply with judicial orders warrants indefinite suspension from legal practice)
- Mojica Sandoz v. Bayamón Federal Savs., 117 DPR 110 (P.R. 1986) (adherence to notarial fee statutes is essential and constitutes a ministerial duty)