KLRA202300580
Tribunal De Apelaciones De Pue...Aug 30, 2024Background
- Deric López Rodríguez (“López”) leased a 2022 Jeep Grand Wagoneer from Popular Auto, acquired via Flagship Chrysler Bayamón (Bella Retail Group/Flagship), with FCA US, LLC as manufacturer.
- López’s vehicle suffered a major breakdown (emitting smoke, ceased to function) two months after acquisition; he delivered it for repair under warranty in October 2022.
- Repairs took approximately 144 days, partly due to delays in sourcing a replacement engine after the first ordered engine did not arrive.
- López filed a complaint with DACO seeking a contract cancellation or a replacement vehicle, arguing unreasonable delay in warranty repair.
- DACO awarded $5,000 in compensation to López for tardy repairs, but denied contract cancellation, finding the defect was eventually cured and covered by warranty.
- On judicial review, López challenged the adequacy of the remedy and the denial of contract cancellation; defendants argued timely performance under warranty and provision of alternate transportation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was $5,000 compensation an adequate remedy for delayed repair? | Delay was unreasonable—contract cancellation warranted | Repairs performed under warranty after reasonable delays due to supply issues; alternate transportation provided | Compensation was adequate; cancellation not warranted |
| Did the administrative agency fail to consider all evidence? | Evidence not fully reviewed | Agency’s decision supported by the record | Agency based decision on substantial evidence |
| Should contract cancellation be granted due to repair delay? | Long delay justified rescission | Delay didn’t rise to level justifying rescission; problem ultimately repaired | No contract rescission granted |
| Should defendants be sanctioned for temerity? | Defendants acted in bad faith | Refuted—actions within range of reasonable conduct | No temerity sanctions imposed |
Key Cases Cited
- Polanco v. Cacique Motors, 165 D.P.R. 156 (P.R. 2005) (explains the doctrine of hidden defects and redhibitory actions in motor vehicle purchases)
- Ford Motor Co. v. Benet, 106 D.P.R. 232 (P.R. 1977) (burden on buyer to prove defective product and reasonable opportunity to cure)
- García Reyes v. Cruz Auto Corp., 176 D.P.R. 870 (P.R. 2008) (summarizes requirements for actions for hidden defects—vicios ocultos)
- Dávila Nieves v. Meléndez Marín, 187 D.P.R. 750 (P.R. 2013) (sets forth appellate review standards)
- Super Asphalt v. AFI, 206 D.P.R. 803 (P.R. 2021) (outlines agency deference and criteria for judicial intervention)