Lebron Cruz, Luis M v. Amgen Manufacturing Limited
KLCE202400135
Tribunal De Apelaciones De Pue...May 20, 2024Background
- Luis M. Lebrón Cruz worked for Amgen Manufacturing Limited (AML) from August 2001 until his dismissal on March 2, 2020.
- Lebrón Cruz filed a complaint alleging unjustified dismissal under Ley 80, and discrimination based on age (Ley 100) and disability (Ley 44), stemming from his major depression and an inflexible work schedule.
- Before his dismissal, Lebrón Cruz had a medically recommended fixed shift due to his condition; AML implemented rotating shifts and denied his request for a reasonable accommodation.
- Lebrón Cruz alleged AML replaced him with younger, less experienced staff and did not have performance issues.
- AML contested the claims, arguing the dismissal was justified due to performance problems, misconduct, and dishonesty during an internal investigation.
- The trial court denied AML’s motion for summary judgment, finding the submitted sworn statements insufficient under Civil Procedure Rule 36.5.
- AML sought certiorari in the appellate court, challenging the trial court’s evidentiary rulings and denial of summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Sworn Statements (Rule 36.5) | Declarations not based on personal knowledge | Declarations are based on personal, job-related knowledge | Sworn statements were admissible and not hearsay |
| Whether Declarations are Hearsay | Some declarations constitute hearsay | No hearsay; if anything, an exception applies | Declarations are not hearsay; fall under business records exception |
| Sufficiency of Evidence for Summary Judgment | Evidence shows factual disputes over discrimination | No material facts in controversy; justified dismissal proven | No genuine dispute; summary judgment proper for AML |
| Duty to Set Out Contested/Incontrovertible Facts | Summary judgment denial appropriate | Trial court failed to state contested/incontrovertible facts | Appellate court reviewed de novo, found no material factual issues |
Key Cases Cited
- Caribbean Orthopedics v. Medshape et al., 207 DPR 994 (discretionary review criteria for certiorari)
- Pueblo v. Rivera Montalvo, 205 DPR 352 (appellate review standards)
- Lugo Montalvo v. Sol Meliá Vacation, 194 DPR 209 (summary judgment mechanism and requirements)
- Roldán Flores v. M. Cuebas, Inc., 199 DPR 664 (requirements for admissible declarations and summary judgment)
- Ramos Pérez v. Univisión, 178 DPR 200 (duties regarding findings of facts in summary judgment rulings)