Quiles Rodriguez, Jose a v. Rodriguez Jorge, Daniel
KLCE202500230
| Tribunal De Apelaciones De Pue... | Apr 30, 2025Background
- José A. Quiles Rodríguez filed a petition for a protection order against Daniel Rodríguez Jorge, his coworker, under Puerto Rico's anti-stalking statute (Law No. 284-1999), following alleged threats related to a workplace theft accusation.
- On February 6, 2025, a hearing was held where Quiles Rodríguez presented audio evidence of threats by Rodríguez Jorge; the latter was present at the hearing.
- The trial court granted a one-year protection order, restricting Rodríguez Jorge from making any contact with Quiles Rodríguez and his family and barring him from certain locations.
- Rodríguez Jorge challenged the order via certiorari, arguing violations of his due process rights and contesting the sufficiency of the evidence supporting a pattern of stalking.
- The Court of Appeals addressed the petition without input from Quiles Rodríguez, as he did not respond within the allotted time.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due Process Violation in Notification | Rodríguez Jorge says insufficient notice of hearing, and right to counsel denied | N/A | Court found sufficient notice and process; hearing was proper. |
| Right to Cross-Examine Evidence | Rodríguez Jorge claims he was not allowed to contest evidence or cross-examine | N/A | Court found no abuse; judge allowed silence for self-protection. |
| Sufficiency of the Evidence under Anti-Stalking Law | Rodríguez Jorge argues no 'pattern of conduct' was proven | Quiles Rodríguez did not respond | Court found evidence sufficient for probable stalking. |
| Appropriateness of Certiorari Review | Rodríguez Jorge requests certiorari to overturn order | N/A | Court declined to issue certiorari, finding no abuse of discretion. |
Key Cases Cited
- Rivera v. Arcos Dorados, 212 DPR 194 (P.R. 2023) (scope and standards for certiorari review)
- Torres González v. Zaragoza Meléndez, 211 DPR 821 (P.R. 2023) (factors guiding certiorari discretion)
- García v. Padró, 165 DPR 324 (P.R. 2005) (definition and limits of judicial discretion)
- Vargas v. González, 149 DPR 859 (P.R. 1999) (presumption of correctness attaches to judicial decisions)
- Torres Martínez v. Torres Ghigliotty, 175 DPR 83 (P.R. 2008) (timing and scope of appellate intervention)