Municipio Autonomo De Manati v. Fdr 1500 Corp
KLAN202400346
Tribunal De Apelaciones De Pue...Jul 31, 2024Background
- The Municipality of Manatí sought to expropriate 54,899.1466 square meters in Mar Chiquita, Manatí, Puerto Rico for public use, particularly to develop a passive ecological park and guarantee access to the beach.
- FDR 1500 Corp. contested the expropriation, arguing lack of legitimate public purpose and improper compensation.
- The Trial Court (TPI) granted a partial summary judgment, finding a valid public purpose and ordering continuation of the expropriation process.
- FDR Corp. appealed, arguing that material factual disputes existed regarding public purpose and that a hearing was required to protect due process rights.
- The Court of Appeals reviewed the case de novo and affirmed the trial court's decision, finding no genuine issue of material fact and upholding the summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether expropriation had a legitimate public purpose | No public purpose; area already protected; project unnecessary | The taking is for ecological preservation, public access, and recreation | Expropriation serves a valid public purpose per legislative determination |
| Adequacy of summary judgment without evidentiary hearing | Existence of material facts required an evidentiary hearing | No factual dispute; summary judgment appropriate under procedural rules | No hearing required, as material facts were not genuinely contested |
| Compliance with procedural requirements for expropriation | Municipality failed to justify necessity and process was flawed | All legal requirements for expropriation and public use were properly met | Municipality complied with all substantive and procedural legal requirements |
| Right to due process in expropriation proceedings | Was denied opportunity to contest and present evidence in hearing | Procedures followed and FDR had opportunity to contest but offered only opinions | Due process satisfied; opposition failed to present admissible contradicting evidence |
Key Cases Cited
- Culebra Enterprises Corp. v. E.L.A., 127 DPR 943 (Presumption of public use in expropriation)
- McCormick v. Marrero Juez, 64 DPR 260 (Legislative discretion in defining public purpose for expropriation)
- Mun. de Guaynabo v. Adquisición M2, 180 DPR 206 (Limits of judicial review in eminent domain proceedings)
- SLG Zapata-Rivera v. J.F. Montalvo, 189 DPR 414 (Summary judgment standards and admissible evidence)