Malave Laboy, Jonathan v. D De Correccion Y Rehabilitacion
KLRA202500104
Tribunal De Apelaciones De Pue...Mar 31, 2025Background
- Jonathan Malavé Laboy was convicted and sentenced to three years for violating Article 127 of the Puerto Rico Penal Code and other offenses.
- Malavé spent time in preventive detention from August 20 to October 3, 2020, and later under various correctional measures, including supervised release and time in rehabilitation.
- In February 2024, privileges were revoked due to noncompliance, and Malavé was reincarcerated, with subsequent periods of detention counted toward his sentence.
- Malavé filed an administrative remedy in January 2025, requesting credit for his earlier preventive detention in 2020, which was initially denied by the Department of Corrections.
- While the appeal was pending, the Department updated Malavé’s sentencing records to include the requested preventive detention period, thereby granting the relief sought.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credit for preventive detention period | Malavé argued he should receive credit for preventive detention from Aug 20 to Oct 3, 2020. | Department initially denied; later conceded and credited the period. | Court held case is moot; relief granted. |
Key Cases Cited
- Freire Ruiz de Val v. Morales Román, 214 DPR _ (Puerto Rico 2024) (Emphasizes the threshold importance of jurisdictional review.)
- Super Asphalt v. AFI y otros, 206 DPR 803 (Puerto Rico 2021) (Clarifies the academic nature of cases mooting judicial intervention.)
- Torres Alvarado v. Madera Atiles, 202 DPR 495 (Puerto Rico 2019) (Reiterates the duty to dismiss nonjusticiable academic cases.)
- Pueblo v. Díaz, Rivera, 204 DPR 472 (Puerto Rico 2020) (Describes the doctrine of justiciability and its limitations on court intervention.)
