Méndez Ruiz v. Techno Plastics Industries, Inc.
2025 TSPR 68
| Supreme Court of Puerto Rico | 2025Background
- Silmarie Méndez Ruiz, an employee of Techno Plastics Industries, suffered a work-related injury in July 2018 and received treatment from the Puerto Rico State Insurance Fund Corporation (CFSE).
- Méndez was reinstated to her job before the expiration of the statutory twelve-month employment reserve period and worked continuously for over two years afterward.
- In February 2021, Méndez experienced a relapse of her condition, leading her to seek additional medical treatment from CFSE; Techno Plastics dismissed her in April 2021, alleging the employment reserve period had expired in July 2019.
- Méndez filed a claim for unjustified dismissal, discrimination, and retaliation under Puerto Rico's summary labor claim procedure.
- Both the trial and appellate courts ruled in favor of Méndez, finding her dismissal unjustified; Techno Plastics appealed to the Supreme Court of Puerto Rico.
Issues
| Issue | Méndez Argument | Techno Plastics Argument | Held |
|---|---|---|---|
| Does returning to CFSE for additional treatment after the reserve period justify dismissal? | Returning for treatment after reserve period does not justify dismissal; she worked for years after reserve expired. | Dismissal was justified because the twelve-month reserve period had expired. | No, returning to CFSE does not constitute just cause for dismissal. |
| Was Méndez’s employment appropriately reserved and reinstated under Law 45? | Techno Plastics complied, but her later relapse did not restart the clock or justify dismissal. | Reserve period expired; thus, no further obligation. | Techno Plastics complied with Law 45 regarding job reservation and reinstatement, but justification for dismissal still failed. |
| Is Méndez entitled to remedies under Law 45 or only under Law 80 for unjustified dismissal? | Entitled to both remedies under Law 45 and Law 80. | Only Law 80 applies; Law 45 not triggered because employment was reserved and reinstated. | Only Law 80 applies; she is entitled to “mesada” (statutory severance), not Law 45 remedies. |
| Applicability of Puerto Rico’s Labor Transformation and Flexibility Act (Law 4-2017) | Inapplicable due to hiring date and facts. | Should apply to limit severance remedy. | Law 4-2017 is inapplicable; pre-2017 Law 80 calculation is used. |
Key Cases Cited
- Rivera v. Blanco Vélez Stores, 155 D.P.R. 460 (P.R. 2001) (interprets the employment reservation and reinstatement requirements under Law 45 for work-related injury cases)
- Cuevas v. Ethicon Div. J&J Prof. Co., 148 D.P.R. 839 (P.R. 1999) (balance between employee protection and employer economic interests in Law 45 cases)
- Ortiz Ortiz v. Medtronic, 209 D.P.R. 759 (P.R. 2022) (standards for unjustified dismissal and application of statutory severance under Law 80)
- Rodriguez v. Méndez & Co., 147 D.P.R. 734 (P.R. 1999) (triggers for Law 45 protections following occupational injury)
- Santos et al. v. Lederle, 153 D.P.R. 812 (P.R. 2001) (purpose and interpretation of employment reservation period in occupational injury cases)