Santaella Jimenez, Alvaro v. El Ryder Memorial Hospital, Inc.
KLAN202400192
Tribunal De Apelaciones De Pue...Jul 17, 2024Background
- The dispute centers on a contract for exclusive neonatal and obstetric services between Hospital Ryder Memorial and Grupo Neonatal, CSP, led by Dr. Santaella.
- The contract provided for automatic renewal unless notification of non-renewal or renegotiation was given 60 days prior to expiration.
- After Hurricane Maria in 2017 caused severe damage to Hospital Ryder (making several floors, including the maternity and neonatal units, inoperable), the hospital later contracted Pediatrix Medical Group to provide similar services.
- Grupo Neonatal sued for breach of contract, seeking injunctive relief, claiming Hospital Ryder violated their exclusivity.
- Hospital Ryder argued that the hurricane made contract performance impossible (doctrina de imposibilidad sobrevenida / rebus sic stantibus), which should excuse performance.
- The trial court granted summary judgment for Grupo Neonatal, ordering Ryder to compensate for the remaining contract term; Ryder appealed, arguing multiple legal and factual errors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence of Breach/Ability to Perform | Ryder breached the contract for exclusive neonatal services by contracting with Pediatrix; hurricane did not nullify the contract | Hurricane caused inoperability, making performance impossible; contract should be suspended or terminated under rebus sic stantibus | Trial court erred: material factual disputes remain as to breach and ability to perform; not suitable for summary judgment |
| Application of Impossibility Doctrine/Rebus Sic Stantibus | Hurricane's effects did not meet requirements for impossibility; contract continued | Hurricane made contract impossibility; doctrine should excuse or suspend performance | Material facts in dispute re: extent of impossibility and applicability of doctrine; requires trial |
| Adequacy of Termination Notice | Termination notice was insufficient to prevent automatic renewal | Proper notice given under contract terms | Factual dispute about notification, contract clauses; to be determined at trial |
| Entitlement to Damages, Fees, Costs | Plaintiff should receive damages/honorarios for breach | Not liable due to impossibility; contest damages and fees without findings of temeridad | Damages/honorarios not awardable yet; not adjudicated till factual matters resolved at trial |
Key Cases Cited
- Casera Foods, Inc. v. Estado Libre Asociado de Puerto Rico, 108 D.P.R. 850 (P.R. 1979) (sets requirements for rebus sic stantibus doctrine in contract revision)
- BPPR v. Sucn. Talavera, 174 D.P.R. 686 (P.R. 2008) (explains modification or extinguishing of contracts in light of unforeseen circumstances)
- Maderas Tratadas v. Sun Alliance, 185 D.P.R. 880 (P.R. 2012) (discusses indemnification for breach of contract)
- González v. Multiventas, 165 D.P.R. 873 (P.R. 2005) (addresses standards for summary judgment in presence of material factual disputes)