Ramos Pagan, Josue J v. Western Auto Puerto Rico, Inc.
KLRA202400489
Tribunal De Apelaciones De Pue...Oct 17, 2024Background
- Josué J. Ramos Pagán filed a complaint before DACO against Western Auto of Puerto Rico, Inc. (Advance Auto Parts) after purchasing a motor for a 2013 Ford Escape that did not meet advertised specifications.
- Ramos Pagán paid for a 2013 motor with 27,000 miles but received a 2014 motor with 102,765 miles. He sought contract rescission, refund, and reimbursement of mechanic costs.
- DACO held an administrative hearing, determined Advance Auto had been properly notified via the address on record, but Advance Auto did not attend and was declared in default.
- DACO ruled in favor of Ramos Pagán, ordering Advance Auto to refund the purchase cost, mechanic costs, and pay an additional $500 penalty for temerity.
- Advance Auto appealed, arguing denial of due process (claiming lack of notice), lack of jurisdiction due to allegedly indispensable parties, and improper award of damages.
- The appellate court reviewed evidence of notification and considered whether DACO’s process and findings met due process and substantive requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of Notice / Due Process | DACO gave proper, timely notice using correct address | Not notified of complaint/hearing, thus denied due process | Notice was proper; due process satisfied. |
| Jurisdiction/Indispensable Party | Ramos Pagán was a direct contracting party | Only mechanic (not Pagán) contracted; Pagán lacked standing | Ramos Pagán had standing; DACO had jurisdiction. |
| Appropriateness of Remedies | Remedies should include refund, penalties, and costs | No basis for damages, penalty, or costs absent a direct contract | Remedies appropriate, but ordered return of engine to Advance. |
| Sufficiency of Administrative Record | DACO's findings based on substantial evidence | No substantial evidence, findings unsupported | Substantial evidence supported DACO's findings. |
Key Cases Cited
- Mun. San Juan v. Plaza Las Américas, 169 DPR 310 (notification is essential for administrative validity)
- Vendrell López v. AEE, 199 DPR 352 (efficacy of notice and due process requirements in administrative context)
- Henríquez v. Consejo Educación Superior, 120 DPR 194 (value of impartial adjudication, proper notice, and evidence in admin. hearings)
- Otero v. Toyota, 163 DPR 716 (deference to agency fact-finding when supported by substantial evidence)
- Rebollo v. Yiyi Motors, 161 DPR 69 (judicial review and presumption of agency decision regularity)