Renatus, LLC v. Municipio De Patillas
KLCE202500474
Tribunal De Apelaciones De Pue...May 21, 2025Background
- Renatus, LLC sued the Municipality of Patillas for breach of contract, collection of money, and damages related to professional consulting services rendered after hurricanes Irma and Maria.
- Renatus claimed it had multiple contracts with the municipality, amended over time to increase their compensation ceiling, and that it was owed $765,281.68.
- The Municipality responded, denying liability, arguing lack of proper contracting procedure, claiming invalidity due to lack of funds and absence of recordation with the Comptroller (as required by Puerto Rico law), and filed a counterclaim seeking contract nullity and recovery of disbursed funds.
- Renatus sought partial summary judgment, asserting no dispute as to material facts and insisting the Municipality approved the relevant invoices.
- The trial court denied summary judgment, citing several material factual disputes, and denied reconsideration; Renatus then sought certiorari review in the Puerto Rico Court of Appeals.
Issues
| Issue | Renatus's Argument | Municipality's Argument | Held |
|---|---|---|---|
| Was summary judgment appropriate given the evidence? | No material facts in dispute; contracts valid and approved; payment due. | Material fact disputes remain: contract validity, compliance with procedures, real services provided. | No, summary judgment inappropriate due to genuine factual disputes. |
| Did the trial court abuse its discretion in denying summary judgment? | TPI failed to identify real controversies or make required factual determinations. | TPI correctly identified several disputed material facts. | No abuse; TPI properly exercised discretion. |
| Was the evidence offered by Renatus sufficient and admissible for summary judgment? | Documentation and self-serving affidavit proved absence of disputes. | Evidence largely inadmissible or self-serving; lacked objective foundation. | Renatus's evidence insufficient; proper summary judgment evidence was lacking. |
| Did procedural errors justify interlocutory certiorari? | Yes; substantial justice required review. | No immediate remedy required; no clear legal error or prejudice. | Certiorari denied; criteria for interlocutory review not met. |
Key Cases Cited
- McNeil Healthcare v. Mun. Las Piedras I, 206 DPR 391 (Puerto Rico 2021) (scope and discretion for certiorari)
- Rivera et al. v. Arcos Dorados et al., 212 DPR 194 (Puerto Rico 2023) (criteria for appellate certiorari)
- Oriental Bank v. Caballero García, 212 DPR 671 (Puerto Rico 2023) (material facts and summary judgment standards)
- S.L.G. Szendrey-Ramos v. Consejo de Titulares, 184 DPR 133 (Puerto Rico 2011) (trial court’s evaluation duties in summary judgment)
- JADM v. Centro Comercial Plaza Carolina, 132 DPR 785 (Puerto Rico 1983) (trial courts must find absence of real controversy for summary judgment)