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Malave Laboy, Jonathan v. D De Correccion Y Rehabilitacion
KLRA202500104
Tribunal De Apelaciones De Pue...
Mar 31, 2025
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Background

  • 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.)
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Case Details

Case Name: Malave Laboy, Jonathan v. D De Correccion Y Rehabilitacion
Court Name: Tribunal De Apelaciones De Puerto Rico/Court of Appeals of Puerto Rico
Date Published: Mar 31, 2025
Docket Number: KLRA202500104