Rosario Reyes, Luis Armando v. Ayala Sierra, Diana, KLAN202401031

Luis A. Rosario Reyes filed a summary eviction (desahucio en precario) lawsuit against Diana Ayala Sierra, alleging he is the owner by inheritance of a property she occupies after the end of their relationship.
Ayala Sierra contended Reyes failed to submit proof of ownership or a declaration of heirs, and that she resided with his consent during the relationship.
The court's order and notice described the hearing as an initial conference, but the judge treated it as a summary dispossession proceeding and moved directly to adjudicate the merits.
Reyes (the plaintiff) did not appear at the hearing; only his attorney presented arguments/testimony, preventing cross-examination or direct factual testimony.
The trial court granted summary eviction in favor of Reyes based on attorney statements, leading Ayala Sierra to appeal claiming violation of her procedural due process rights.
On appeal, the appellate court focused on whether the trial judge's process complied with due process and statutory requirements for this type of summary eviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was adjudicating the case without plaintiff's presence and based solely on attorney statements valid?	Arguments/testimony by attorney were sufficient to establish ownership and right to eviction.	Defendant was denied opportunity to confront/contradict factual testimony, violating due process.	No, this violated due process; attorney cannot substitute for witness testimony.
Did the procedure used comport with statutory and constitutional due process?	Procedure was appropriate as a summary process per desahucio rules.	Clerk misnotified parties; parties were unprepared for a merits hearing, creating confusion and prejudice.	No, notice and opportunity to be heard were inadequate; fairness required conversion to ordinary process.
Was sufficient evidence of ownership provided to support eviction?	Documented ownership via inheritance and submitted usage permit.	No adequate proof of title or declaration of heirs presented at hearing.	No, plaintiff failed to provide necessary real evidence of ownership.
Should the order of eviction be reversed and proceedings conducted anew?	Urged affirmance of summary judgment and ejectment based on record.	Sought reversal and remand for full hearing with opportunity to contest evidence.	Yes, reversed and remanded for proceedings as an ordinary case with proper process.

Mora Dev. Corp. v. Sandín, 118 DPR 733 (Puerto Rico 1987) (explains summary eviction nature and requirements)
C.R.U.V. v. Román, 100 DPR 318 (Puerto Rico 1971) (confirms summary nature of desahucio and necessary proof)
Meléndez v. Pacheco, 75 DPR 95 (Puerto Rico 1953) (outlines burden in desahucio: proving ownership and defendant's lack of right)
Ades v. Zalman, 115 DPR 514 (Puerto Rico 1984) (attorneys should not serve as witnesses in lieu of parties)
Trinidad v. Chade, 153 DPR 280 (Puerto Rico 2001) (appellate review standards for documentary evidence)