Municipio De San Juan v. Citizens Renovation & Dev Corp, KLAN202300156

Municipality of San Juan filed for forced expropriation on June 16, 2000 to acquire two parcels for the Península de la Cantera project and initially deposited $59,750.00.
After litigation and revaluation, the parties agreed the fair compensation was $800,000.00; the Municipality made additional consignments in 2019, bringing total deposits to $800,352.57.
The Trial Court (TPI) awarded $800,000.00 plus interest, directing interest to be computed compounded semester-to-semester from date of incautación to payment, following Aut. Carreteras precedent.
The Municipality appealed, arguing Section 5(b) of the Expropriation Law (as amended by Law 167‑2015) and related municipal law require simple (not compound) interest and that interest is determined at the time of judgment.
Citizens (the landowner) argued that compounded interest should apply and that the post‑expropriation statutory amendments could not be applied retroactively to reduce its compensation.
The Court of Appeals modified the TPI judgment solely to require calculation of interest on a simple basis and remanded for recalculation consistent with Section 5(b).

Issue	Plaintiff's Argument (Municipio)	Defendant's Argument (Citizens)	Held
Method of computing interest (simple vs. compound)	Section 5(b) (as amended) and municipal law require interest be computed on a simple basis	Compound interest applies based on prior Aut. Carreteras decisions and to avoid retroactive impairment of rights	Interests must be computed simple, not compound; TPI erred in applying compound interest; case remanded for simple-interest computation
Applicability/retroactivity and start/date of accrual	Statutory scheme determines interest at time of judgment and mandates simple calculation; procedural statutes apply retroactively	Applying post‑expropriation amendments would retroactively diminish Citizens’ rights because expropriation occurred in 2000	Section 5(b) governs and applies to computation method; interest is compensatory from date of incautación to payment but is to be computed simple under the governing statute; procedural changes that benefit litigants apply retroactively

Autoridad de Carreteras v. 8,554.741 m/c II, 172 D.P.R. 1050 (2008) (discusses semester‑by‑semester interest and prior adoption of compound computation in expropriation context)
Autoridad de Carreteras v. 8,554.741 m/c I, 172 D.P.R. 278 (2007) (addresses consideration of varying interest rates across semestres and expectation of reasonable return)
E.L.A. v. Rexco Industries, 137 D.P.R. 683 (1994) (frames interest as integral compensatory element of just compensation; Legislature sets computation method)
Pamel Corp. v. E.L.A., 124 D.P.R. 853 (1989) (states that expropriation compensation includes value at time of incautación plus corresponding interest)
Adm. Terrenos v. Ponce Baylánd, 207 D.P.R. 586 (2021) (defines "just compensation" as market value at time of expropriation and best reasonably probable use)