Rios Mendoza, Lerida I v. Depto De Desarrollo Economico Y Comercio
KLRA202400471
| Tribunal De Apelaciones De Pue... | Aug 29, 2024Background
- Lérida I. Ríos Mendoza appealed a determination made by the Oficina de Gerencia de Permisos (OGPe), an administrative agency in Puerto Rico under the Department of Economic Development and Commerce (DDEC).
- Ríos Mendoza's filing included incomplete documentation: only the first three pages of an eleven-page public hearing report and other supporting documents, but lacked a final order or notification necessary for appellate review.
- The case related to a complaint filed by Ríos Mendoza regarding a business dispute, but the administrative record submitted was insufficient for judicial assessment.
- The court emphasized the importance of strict compliance with procedural requirements for judicial review of an administrative agency's final action under the Ley de Procedimiento Administrativo Uniforme (LPAU).
- The Appellate Court, composed of Judges Ortiz Flores, Aldebol Mora, and Boria Vizcarrondo, reviewed whether they had jurisdiction, given the deficiencies in the submission.
- The appeal was ultimately dismissed for failing to comply with procedural rules regarding jurisdiction and the contents of the administrative record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether appellate review was proper without a final agency determination. | Ríos Mendoza sought review based on incomplete records, claiming there was an agency decision suitable for appeal. | OGPe position not formally noted, but record suggests lack of a final appealable order. | Dismissed: No jurisdiction without a final adjudication or full administrative record. |
| Whether the administrative record sufficed for the court’s jurisdiction. | Ríos Mendoza provided partial records, believing this fulfilled the requirement. | Implied: OGPe did not respond due to deficient notice/procedure. | Dismissed: Failure to provide required documents is fatal to jurisdiction. |
| Compliance with filing and notice requirements for judicial review. | Ríos Mendoza did not fully comply but sought leniency due to pro se, pauperis status. | Implied: Record silent, but strict rules govern procedural compliance. | Dismissed: Procedural requirements must be strictly followed regardless of status. |
| Whether procedural deficiencies can be excused in the interest of justice. | Ríos Mendoza argued for broad access to justice and leniency. | Implied: Not directly argued. | Dismissed: Jurisdictional and procedural rules are determinative. |
Key Cases Cited
- Santos Serrano v. ELA, 162 DPR 870 (P.R. 2004) (judicial review limited to final agency adjudications)
- Padilla Falú v. Administración de Vivienda, 155 DPR 183 (P.R. 2001) (premature appeals from non-final decisions are improper)
- Rodríguez Díaz v. Zegarra, 150 DPR 649 (P.R. 2000) (officers not authorized to issue final resolutions)
- MCS Advantage v. Fossas Blanco et al., 211 DPR 135 (P.R. 2023) (general jurisdiction subject to subject-matter limitations)
- Yumac Home v. Empresas Massó, 194 DPR 96 (P.R. 2015) (courts must examine their own jurisdiction sua sponte)
- COSVI v. CRIM, 193 DPR 281 (P.R. 2015) (LPAU deadlines are strict jurisdictional requirements)
- Rodríguez v. Junta de Directores del Condominio Monte Sur, 144 DPR 742 (P.R. 1998) (judicial review limited to the administrative record)