Inmobiliaria Moreno De Ayala, Inc v. Ortiz Garcia, Mario Alejandro
KLAN202500439
Tribunal De Apelaciones De Pue...May 22, 2025Background
- Inmobiliaria Moreno de Ayala, Inc. sued Mario Alejandro Ortiz García for breach of contract and collection of money in the San Juan Superior Court.
- The trial court entered judgment for Inmobiliaria Moreno, against Ortiz García.
- Ortiz García appealed pro se to the Puerto Rico Court of Appeals, seeking reversal of the judgment.
- The appeal failed to comply with the procedural rules for civil appeals, notably lacking a concise statement of facts, discussion of errors, and critical documentary appendices.
- The appellate court reviewed whether it had jurisdiction to consider the appeal, given these omissions.
- The Court of Appeals dismissed the appeal for lack of jurisdiction based on non-compliance with appellate procedural requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Compliance with procedural rules | Inmobiliaria argued strict adherence required for appellate review | Ortiz García claimed appeal should be heard despite omissions | Court held that strict compliance is required; non-compliance warrants dismissal |
| Jurisdiction to hear appeal | Inmobiliaria contended defects deprived the court of jurisdiction | Ortiz García did not dispute jurisdiction, focused on merits | Court concluded it lacked jurisdiction due to procedural defects |
| Sufficiency of appellate brief | Inmobiliaria pointed to missing elements in Ortiz's brief | Ortiz García provided only minimal assertions and no supporting documents | Court found the brief insufficient and not in compliance |
| Effect of pro se representation | Not argued as excusing non-compliance | Ortiz García appeared pro se | Court held pro se status does not exempt from procedural requirements |
Key Cases Cited
- Miranda Corrada v. DDEC, 211 DPR 738 (P.R. 2023) (jurisdiction is fundamental and may be raised at any stage)
- Beltrán Cintrón v. ELA, 204 DPR 89 (P.R. 2020) (courts must promptly address jurisdictional defects)
- Soto Pino v. Uno Radio Group, 189 DPR 84 (P.R. 2013) (strict compliance with appellate rules is required)
- Hernández Maldonado v. Taco Maker, 181 DPR 281 (P.R. 2011) (failure to perfect appeal as prescribed may result in dismissal)