Rodriguez Santiago, Karitza I v. Jose Echevarria Diseñador, Corp.
KLAN202401125
Tribunal De Apelaciones De Pue...Mar 24, 2025Background
- Karitza I. Rodríguez Santiago began working for José Echevarría's company in June 2014 on an open-ended employment contract.
- In June 2023, Rodríguez Santiago had a workplace confrontation with another employee (her ex-partner), resulting in a verbal warning from Echevarría.
- On December 20, 2023, Rodríguez Santiago was involved in a second, more serious workplace incident, where she was described as having an intimidating and hostile attitude in the workplace.
- Following the second incident, Echevarría asked her to gather her things and leave; there was no formal written notice of termination.
- Rodríguez Santiago filed a complaint alleging unjustified dismissal under Puerto Rico Ley Núm. 80-1976; the employer claimed the firing was for insubordination.
- The trial court ruled against Rodríguez Santiago; she appealed, arguing the dismissal was without just cause.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the dismissal was unjustified under Ley Núm. 80-1976 | Rodríguez: No just cause for dismissal; actions did not justify termination | Echevarría: Dismissal was for insubordination and justified under company rules | Dismissal was justified due to insubordination, upheld by the court |
| Need for formal written notice of dismissal | Rodríguez: Lack of formal notice invalidates termination | Echevarría: Oral instruction to leave constituted dismissal | Lack of formal notice did not invalidate dismissal |
| Whether single incidents can justify immediate dismissal under Ley 80 | Rodríguez: Law disfavors dismissal for a first offense | Echevarría: Severity of conduct justified immediate dismissal | Serious first offense (insubordination) can justify dismissal |
| Constructive discharge claim | Rodríguez: Workplace conditions were intolerable | Echevarría: Actions were justified, not arbitrary or capricious | No constructive discharge found |
Key Cases Cited
- Rivera v. The Brusch Co., 180 D.P.R. 894 (P.R. 2011) (constructive dismissal requires arbitrary, capricious employer conduct creating a hostile environment)
- SLG Zapata-Rivera v. J.F. Montalvo, 189 D.P.R. 414 (P.R. 2013) (just cause for dismissal must relate to proper functioning of the business)
- Indulac v. Central General de Trabajadores, 207 D.P.R. 279 (P.R. 2021) (dismissal for serious first offense may be justified under Ley 80)