Martinez, Jose Ulises v. Utier
KLCE202500346
Tribunal De Apelaciones De Pue...May 19, 2025Background
- José Ulises Martínez Vázquez filed a lawsuit against the Puerto Rico Electric Power Authority (AEE) and UTIER claiming breach of contract related to payment for union leave during a negotiation hiatus.
- AEE served Martínez Vázquez with a set of interrogatories, document requests, and requests for admissions on December 10, 2024, granting him 30 days to respond.
- Martínez Vázquez failed to respond to the request for admissions within the specified timeframe and later sought a retroactive extension, citing advanced age and lack of resources.
- On January 21, 2025, the trial court deemed the requests for admissions admitted due to untimely response.
- Martínez Vázquez filed motions to reconsider, arguing, among other things, that the admitted facts were at odds with the results of prior litigation and constituted res judicata.
- The trial court denied reconsideration, leading Martínez Vázquez to seek certiorari review in the appellate court, which was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether requests for admissions must specify a response deadline to be deemed admitted | Deadline not clear in instructions; thus, cannot be held to it | Deadline was proper and even longer than required by rule | Deadline was clear; responses late |
| Whether technical noncompliance trumps substantive justice | Technicalities should not override merits | Procedural rules are mandatory and enforce judicial efficiency | No abuse of discretion by lower court |
| Whether admitted facts can conflict with prior resolved litigation (res judicata) | Facts should not be deemed admitted if previously settled | Plaintiff failed to timely object or respond | No relief; admissions stand |
| Whether extraordinary review (certiorari) is warranted under the circumstances | Lower court abused discretion | No abuse; rules properly applied | Certiorari denied; no judicial error |
Key Cases Cited
- Caribbean Orthopedics v. Medshape et al., 207 DPR 994 (guidance on certiorari and abuse of discretion standard in appellate review)
- Mun. Caguas v. JRO Construction, Inc., 201 DPR 703 (standards for certiorari and trial court discretion)
- SLG Fernández-Bernal v. RAD-MAN et al., 208 DPR 310 (appellate review limitations in procedural matters)
- Audiovisual Lang. v. Sist. Est. Natal Hnos., 144 DPR 563 (purpose and procedure for requests for admissions)
- Rivera Prudencio v. Mun. de San Juan, 170 DPR 149 (strict compliance required for requests for admissions)