Sauri Davila, Nayda v. Power Motor & Parts, Inc
KLRA202500172
Tribunal De Apelaciones De Pue...May 28, 2025Background
- Nayda Saurí filed a complaint with DACo against Power Motor & Parts, Inc., alleging she bought a defective car engine for $3,300, which Power Motor failed to properly repair after several attempts.
- DACo initially ruled in Saurí's favor when Power Motor did not attend the administrative hearing, ordering a refund.
- Power Motor subsequently requested reconsideration, explaining its absence and asking for a new hearing.
- DACo granted reconsideration, annulled the previous resolution, and scheduled a new administrative hearing.
- Saurí appealed to the Court of Appeals, arguing DACo erred by allowing Power Motor's reconsideration without attorney representation and by denying her due process.
- The Court of Appeals dismissed Saurí's appeal for lack of jurisdiction, concluding there was no final agency decision to review yet.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether DACo erred by accepting Power Motor's reconsideration request without legal representation | Saurí argued this violated DACo's rules and LPAU | Power Motor asserted its request was timely and proper | Court held DACo was authorized to accept reconsideration as timely submitted |
| Whether DACo's action denied Saurí the right to due process and to submit her own reconsideration | Saurí claimed DACo's order impaired her procedural rights | (Implied) DACo followed proper process, allowing new hearing | Court found due process not violated and both parties can argue at new hearing |
| Whether the Court of Appeals had jurisdiction to review DACo's decision | Saurí sought immediate review of DACo's interim order | Power Motor argued the matter was not yet final | Court lacked jurisdiction; no final order present |
Key Cases Cited
- Otero Rivera v. Bella Retail Group, Inc., 2024 TSPR 70 (deference owed to administrative agency decisions)
- Graciani Rodríguez v. Garage Isla Verde, 202 DPR 117 (outlines deference to administrative entities)
- Rolón Martínez v. Supte. Policía, 201 DPR 26 (judicial review defers to administrative discretion)
- González v. Mayagüez Resort & Casino, 176 DPR 848 (lack of jurisdiction requires dismissal)