Megill Segarra, Regino v. Sistema Retiro De La Universidad De Pr
KLRA202500044
Tribunal De Apelaciones De Pue...Apr 30, 2025Background
- Regino Megill Segarra (the appellant) retired from the University of Puerto Rico (UPR) in 2023 and applied for retirement benefits from UPR’s Retirement System.
- Megill claimed UPR’s Retirement System should credit him for 17 years of service as a teacher with Puerto Rico’s Department of Education, for which he claimed to have made pension contributions.
- UPR’s Retirement System awarded him a pension based only on service time with UPR, citing no evidence of a completed transfer of contributions from the Teachers’ Retirement System.
- UPR notified Megill he needed to ensure transfer of his past contributions before his employment ended; their system showed no such transfer was completed.
- Megill administratively appealed, arguing the documentary evidence of his prior service and contributions was sufficient, but the agency denied his appeal.
- Megill sought judicial review, arguing the agency erred in not crediting his Department of Education service.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Whether UPR Retirement System erred in not crediting years served in Department of Education | Documents from Teachers’ Retirement System certify 17 years of service and corresponding contributions, which should be recognized | No evidence in the records or agency’s database that the required transfer of contributions was ever completed; only UPR service is credited | No error; agency action was reasonable based on substantial evidence; transfer was never completed |
| Adequacy of evidence to overcome presumption of correctness in the agency’s decision | Documentary evidence provided is sufficient to show service and contributions | Evidence does not show funds were actually transferred; agency’s records support their decision | Plaintiff’s evidence insufficient to overcome presumption of correctness |
| Whether agency acted arbitrarily or unreasonably | Agency ignored official certifications and deprived Megill of earned benefit | Agency followed procedures and based decision on available records | Agency did not act arbitrarily, illegally, or without reason |
| Appropriate standard of proof in administrative proceedings | Agency should be required to act on moral certainty or clear evidence provided | Preponderance of the evidence applies; agency decisions based on substantial evidence | Agency’s factual determinations supported by substantial evidence |
Key Cases Cited
- OEG v. Martínez Giraud, 210 DPR 79 (2022) (courts must ensure agencies act within their statutory powers)
- Pérez López v. Depto. Corrección, 208 DPR 656 (2022) (deference to agency decisions where supported by substantial evidence)
- Torres Rivera v. Policía de PR, 196 DPR 606 (2016) (outlines bases for judicial reversal of agency decisions)
- Rolón Martínez v. Supte. Policía, 201 DPR 26 (2018) (agency interpretations given deference unless irrational)
- Capó Cruz v. Jta. de Planificación et al., 204 DPR 581 (2020) (substantial evidence is that which a reasonable mind might accept as adequate)
- Rebollo v. Yiyi Motors, 161 DPR 69 (2004) (clarifies the substantial evidence standard)